This article was originally posted on Steve Leimberg’s Business Entities Email Newsletter Archive Message #2924.
Smaldino, a recent Tax Court decision, provides several important lessons for practitioners to consider about how to approach structuring and implementing estate plans for certain clients, especially for clients that practitioners did planning for during the rush throughout 2020 and 2021, where many clients came to practitioners fearing dramatic changes in the tax laws and who completed planning in a compressed time frame. While Smaldino can be viewed as just another bad fact case (leaving aside the valuation discussions), that would be a mistake. It provides good reminders of formalities that too often are overlooked.
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