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The
Strangi case was remanded in part to the Tax Court
by the Fifth Circuit. The Court reversed the Tax
Court’s denial of the IRS’s application
to amend its pleadings to add a claim that the
transferred assets were included in the decedent’s
estate under IRC section 2036.
http://www.ca5.uscourts.gov/opinions/pub/01/01-60538-cv0.htm
The IRS issued notice 2002-59 explaining its
standards for evaluating life insurance contracts
in the context of split-dollar arrangements.
http://www.irs.gov/pub/irs-drop/n-02-59.pdf
The IRS issue revised Form 706 and instructions.
Note that these are applicable only for 2002 decedents.
http://www.irs.gov/pub/irs-pdf/f706.pdf
http://www.irs.gov/pub/irs-pdf/i706.pdf
The Tax Court held that Family Limited Partnerships
created by the decedent approximately two years
before his death were validly created, but the
transferred assets were included in his estate
because the Court found an implied agreement that
the decedent would retain the economic benefit
of contributed property.
http://www.ustaxcourt.gov/InOpHistoric/Thompson9.TCM.WPD.pdf
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