Article on Defined Value Clauses

Wendy C. Gerzog recently published her article entitled, Wandering Far Afield with Defined Value Clauses, 135 Tax Notes 9 (2012). An abstract from the article available on SSRN is below:

The Wandry decision extends the application of defined value clauses beyond those family limited partnership cases that transfer any excess value to a charity. In Wandry, the Tax Court reads Procter narrowly and ignores the fundamental rationale of Robinette.