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QTIP Election Valid Where the Will Allowed Reduction in the Surviving Spouse's Interest: Estate of Rinaldi v. Commissioner

In Estate of Rinaldi v. United States, the Court of Federal Claims held that the provision in a will allowing the decedent's son to purchase stock from a trust at below fair market value violated section 2056(b)(7)(B)(ii)(I) and (II), and therefore prevented the trust from qualifying for a qualified terminable interest property ("QTIP") marital deduction under section 2056(b)(7). ...

June R. Kitagawa

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