Marissa Dungey

Withers Bergman

Marisa focuses on tax and estate planning for high-net-worth individuals and their families.

Trusts Can Materially Participate in Trade or Business
The recent decision in Frank Aragona Trust v. Commissioner was a big taxpayer victory that provides much needed guidance for trusts that own business interests.
Unwrapping the Net, Net Gift 
James I. Dougherty & Marissa Dungey address the recent Steinberg decision and the controversial net, net gift technique
IRS Provides Relief for Small Estates to Make a Late Portability Election
In Revenue Procedure 2014-18 issued on Jan. 27, 2014, the Internal Revenue Service announced a simplified method for certain taxpayers to make a portability election for smaller estates that didn’t timely file an estate tax return to elect portability.
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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