25.2511-1 Archives

McDougall v. Commissioner: Navigating the Complexities of QTIP and Gift Tax

Cases, Estate Administration, Estate and Gift Tax, Estate Planning, Tax, Tax Controversy, Tax Court

Dec 4, 2024

The recent Tax Court decision in McDougall v. Comm’r, 163 T.C. No. 5 (2024) provides important insights into the intersection of Qualified Terminable Interest Property (QTIP) trusts and the associated gift tax implications. This article delves into the case’s facts, legal issues, court holdings, and practical implications for estate planners and tax professionals. Factual Background…
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Revisiting Intrafamily Loans – Bolles

Cases, Court of Appeals, Estate and Gift Tax, Estate Planning, Tax

Jun 4, 2024

The Ninth Circuit Court of Appeals recently affirmed a Tax Court opinion dealing with the effect of lifetime transfers by a mother (Mary) to her son (Peter).[1] At issue was the nature of those transfers. On the one hand, Mary Bolles and her estate argued that the transfers constituted loans from Mary to Peter. On…
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Tag: 25.2511-1

McDougall v. Commissioner: Navigating the Complexities of QTIP and Gift Tax

Revisiting Intrafamily Loans – Bolles

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Mississippi Supreme Court Reverses Alimony Award Between Two Estates

Creditor Rights to Beneficiary Interests in Irrevocable Trusts

Ivison – A Review on Amendments to Probated Claims