Tag: trust

From Schedule I to Schedule III: Tax and Estate Planning Consequences of Rescheduling State-Licensed Medical Marijuana

Uncategorized

On April 22, 2026, Acting Attorney General Todd Blanche signed a final order (“Final Order”)[1] immediately rescheduling state-licensed medical marijuana from Schedule I to Schedule III of the Controlled Substances Act (“CSA”),[2] pursuant to President Trump’s 2025 Executive Order directing federal agencies to expedite the rescheduling of medical marijuana.[3] This change may materially affect the…
Read More

Lapsed Life Insurance Policy Generated Taxable Income and Limited Interest Deductions

Income Tax, Tax Controversy, Tax Court

A recent United States Tax Court memorandum[1] opinion provides an important reminder that life insurance policies with outstanding loans can create unexpected income tax consequences when the policy lapses or is surrendered.[2] In Sawyer v. Commissioner, the Tax Court held that a taxpayer realized taxable income when the cash surrender value of his life insurance…
Read More

The Use of Letters of Wishes in Trust Administration

Estate Planning, Fiduciaries

What provides a trustee with information about a settlor’s intent in administering a trust? Obviously, the trust agreement is the most relevant document. However, trust agreements are not always clear, do not always provide context, tend to lack more personal statements of the settlor, and raise many other aspects that could benefit from knowing the…
Read More

Supervisory Approval and the Assertion of Penalties: Palmwood Holdings, LLC v. Comm’r

Charitable Giving, Income Tax, Tax, Tax Controversy, Tax Court

In Palmwood Holdings, LLC v. Comm’r, the United States Tax Court granted partial summary judgment in favor of the IRS, holding that the Service satisfied the supervisory approval requirement of section 6751(b) with respect to a civil fraud penalty first asserted in the IRS’ answer. The decision reinforces a growing body of Tax Court precedent…
Read More

Recent Appellate Case Addresses Undue Influence

Estate Administration, Estate and Trust Controversy, Estate Planning

Estate disputes often rest on a fragile balance between testamentary intent and certain legal safeguards that protect vulnerable testators from improper third-party influence[1]. A recent decision[2] by the Mississippi Court of Appeals highlights this delicate balance and provides commentary on Mississippi’s treatment of undue influence, the role of witness credibility, and the evidentiary burdens faced…
Read More

Inter Vivos QTIP Trusts: A Strategic Estate and Asset Protection Planning Option

Uncategorized

Estate planning requires the careful balancing of family priorities with tax and asset protection concerns, and the tools available to practitioners to address these priorities and concerns change over time amid legislative reforms and judicial determinations. Among the tools available to practitioners, the inter vivos Qualified Terminable Interest Property trust, aka the inter vivos “QTIP”…
Read More

Directions

Oxford Jackson
Call 662-371-4110 Directions Directions