Wandry v. Commissioner: The Secret Sauce Estate Planners Have Been Waiting For?

Volume 26 No 6

By

Tiffany B. Carmona is a senior vice-president and associate fiduciary counsel in the Chicago office of Bessemer Trust. Tye J. Klooster is a partner in the Chicago office of Katten Muchin Rosenman LLP. This article reflects the views of the authors only and does not constitute legal or tax advice.

Taxpayers have grappled with this dilemma of transferring a hard-to-value asset, such as an interest in a closely held business, to an irrevocable trust and risking an IRS challenge to the valuation of the transferred interest and asserting a gift tax deficiency. The most recent taxpayer victory in Wandry v. Commissioner may be a game-changer on this issue.

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