Dawn S. Markowitz

Dawn
S. Markowitz
Legal Editor,
Trusts & Estates

Dawn S. Markowitz is a legal editor at Trusts & Estates magazine. Prior to working at T&E, she was a legal editor at The National Law Journal and at the Institute for Continuing Legal Education. She was formerly a commercial litigator at Shea & Gould and Ashinoff, Ross & Korff, both in New York. She is licensed to practice law in New York.

Articles
Wealth Advisors with Heart: Eido Walny
Despite his extremely busy practice at the Walny Legal Group LLC—the boutique firm he founded in 2011—Eido Walny dedicates a portion of his pro bono time to helping Holocaust survivors and the families of those who didn’t survive.
Wealth Advisors with Heart: Shane Phillips
In 1989, 16-year-old Shane Phillips was in Corsica, France, about to embark on an exciting year abroad when his father, mother and sister died in a plane crash. Beyond the emotional devastation Shane endured, he was faced with another obstacle: His parents had done no financial planning.
Wealth Advisors with Heart: Robert Pagliarini
Robert Pagliarini co-founded The Band of Brothers, a charitable organization focused on improving the quality of life in Southeast Asia.
Wealth Advisors with Heart: Layton John
Traumatic brain injuries—also known as “TBIs”—have received a lot of press in the context of football injuries. But for Layton John, they hit home in 1999.
Wealth Advisors with Heart: James G. Blase
What differentiates JIm Blase, the principal of Blase & Associates LLC, adjunct professor at the St. Louis School of Law and prolific author from other estate-planning practitioners, is his commitment to making sure people have food on their tables.
Contributions to IRAs and CESAs
In this PLR, the IRS ruled that a taxpayer who submits a letter of authorization (LOA) to make a contribution to an existing IRA or CESA is deemed to have made a contribution on the last day of the preceding taxable year, so long as the LOA is postmarked or transmitted within the time prescribed by law for filing the taxpayer’s tax return.
Donating LLC Interests to an Irrevocable Trust
Does a proposed donation of limited liability company membership interests in a decedent’s estate to an irrevocable trust constitute self-dealing?
Charitable Deductions, Disqualified Persons and the Excess Business Holdings Tax
The IRS ruled that a surviving spouse’s estate could claim a charitable deduction for assets passing to three charitable lead annuity trusts. The CLATs, created under the surviving spouse’s revocable trust, included assets passing from a marital trust created under a revocable trust of the predeceased spouse.
Family Trust Assets
In a recent Private Letter Ruling, the Internal Revenue Service concluded that the value of assets held in a family trust aren’t includible in a decedent’s gross estate, except for the value of a “5 or 5” power held by a decedent at his death.
Complete or Incomplete Gifts?
In Private Letter Ruling 201426014 (June 27, 2014), the Internal Revenue Service issued four rulings in relation to property held in an irrevocable trust.
Mandatory Penalties for Late Returns
In Liftin v. United States, the U.S. Court of Appeals for the Federal Circuit affirmed a Court of Federal Claims’ finding that a penalty for a late-filing estate tax return was mandatory.
Proposed Division of a QTIP Trust
In a recent Private Letter Ruling, the Internal Revenue Service issued five rulings regarding the federal income and gift tax consequences of a proposed division of an irrevocable trust.
Marital Deduction for Full Amount Denied
In Chief Counsel Advice 201416007 (released April 18, 2014), the IRS denied a marital deduction under IRC Section 2056 for the full amount of an elective share provided by state law.
Estate Tax Liability Installments Denied
In Woodbury v. Commissioner, the Tax Court granted summary judgment in favor of the Internal Revenue Service, based on a finding that an estate failed to timely make an election to pay estate taxes in installments.
Res Judicata Not a Bar to Beneficiary Liability
In United States v. Whisenhunt, the U.S. District Court for the Northern District of Texas, Dallas Division, adopted a magistrate’s conclusion that an estate beneficiary was personally liable for the estate’s unpaid tax liabilities as the recipient of an individual retirement account distribution.
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