IRC § 2053 Protective Claims for Refund Using New Schedule PC

Probate & Property Magazine: Volume 27 No. 06


Ryan A. Walsh is an associate in the Chicago, Illinois, office of Hamilton Thies & Lorch LLP and the vice-chair of the Estate and Gift Tax Committee.

Following the procedures set forth in Rev. Proc. 2011-48 for IRC § 2053 protective claims is important because if such procedures are not followed, a taxpayer will be subject to all of the generally applicable provisions governing claims for refund and will not have the benefit of the limited review described in Notice 2009-84 and section 5.01 of Rev. Proc. 2011-48.

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