After a 2006 opinion from the U.S. Court of Appeals for the Fifth Circuit in McCord v. Commissioner,1 many practitioners expanded their use of defined value clauses for certain transfer tax planning strategies. But many lawyers remained reluctant to implement the technique without further assurance. Although McCord offered positive precedent, particularly in the Fifth Circuit's jurisdiction, the cautious noted that the decision did not address head-on the Internal Revenue Service's public ...

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