Tax Court Holds Transfers to Descendants Bonda Fide

Wendy S. Gerzog

(professor of law, University of Baltimore) has posted on SSRN her article entitled Flp in the Black, Tax Notes, Vol. 127, No. 3, 2010.

The abstract of the article is below:

In Estate of Black, because the Tax Court held the Blacks’ transfers fell within the bona fide sales exception of section 2036, they were successful at avoiding the application of the provision. Thus, they were able to obtain valuation discounts for their transfers of property (mostly marketable securities) to their son and grandchildren. The court also decided the marital trust funding valuation date issue in the executor’s favor and allowed almost half of the claimed administrative expense deductions.