James focuses on taxation, estate planning, and probate issues issues for high net worth individuals and families. He has also been involved in advising clients on the IRS Voluntary Disclosure programs.
In CCA 201330033, the IRS stated that the mortality tables didn’t apply to value the self-cancelling installment note (SCIN); rather the transferor’s life expectancy had to be considered in light of his particular medical history as of the date of the gift to determine the value of the SCIN.
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