PLR 201206019: Sale By Estate to Disqualified Person Not Self-Dealing

The IRS recently held in a Private Letter Ruling that a private foundation that has an expectancy in a decedent’s estate does not engage in self-dealing when it sells property to a disqualified person via a promissory note. The IRS ruled that “so long as the sale…by [the estate]to disqualified persons qualifies as a transaction during the administration of an estate under 53.4941(d)-1(b)(3) of the foundation regulations…the sale transaction is not self-dealing.”

See Marc Hoffman, Sale of Property to Disqualified Person with Promissory Note Not Self-Dealing, Planning Giving Design Center, Jan. 13, 2012; Andrew Hodes, PLR 201206019: Sale of Property to Disqualified Person Via Promissory Note Not Self-Dealing, Wealth Strategies Journal 2.0 (Beta), Feb. 16, 2012.

Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.