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Robin Klomparens

Suggested Procedure for Filing and Perfecting Protective Claims Under Treasury Regulations §20.2053-1

September 30, 2010

IRC §2053(a)(3) states, in relevant part, that, “[f]or purposes of [the federal estate tax], the value of the taxable estate shall be determined by deducting from the value of the gross estate such amounts … for claims against the estate … as are allowable by the laws of the jurisdiction … under which the estate […]

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Qualified Personal Residence Trust

August 30, 2010

Although estate tax only occurs upon one’s death, it has in prior years reached almost sixty percent (60%).  It is currently thirty-five percent (35%) for two years and will remain at that rate until new legislation is enacted for 2013 and beyond.  Upon an individual’s death, his or her entire estate over the exemption amount […]

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Current Developments in Estate Planning – 2010 Tax Act

August 30, 2010

2010 Estate Tax Election Although EGTRRA provided for no federal estate tax for decedents dying in 2010, Congress’ passage of the Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010 modified the 2010 repeal.  Rather than having no estate tax, estates of decedents dying in 2010 are now generally subject to estate tax.  […]

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Exit Strategies in Estate Planning & Pertinent Tax Issues

May 30, 2010

Sale of Stock or Assets. Stock.  A stock sale is simpler than an asset sale, and will result in one level of tax to the selling shareholders of a C-corporation.  With an S-corporation that does not have C-corporation earnings and profits, or in the case of an unincorporated business treated as a partnership for federal […]

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Estate Planning on the 2010 Crazy Train

March 31, 2010

Power of Appointment Causes – Inclusion in Decedent’s Estate Technical Advice Memorandum 200907025 (TAM 200907025) Decedent was the sole beneficiary of a trust over which he was granted a power of appointment.  An issue arose as to whether the power of appointment was a general power of appointment for IRC section 2041 purposes.  The language […]

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Navigating Audit, Appeals and Litigation: The IRS’ Perspective

March 30, 2010

Power of Appointment Causes-Inclusion in Decedent’s Estate Technical Advice Memorandum 200907025 (TAM 200907025) Decedent was the sole beneficiary of a trust over which he was granted a power of appointment.  An issue arise as to whether the power of appointment was a general power of appointment for IRC section 2041 purposes.  The language of decedent’s […]

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