The Tax Court’s March 26, 2012 memorandum decision in Wandry v. Commissioner1 is monumental for defined value clause (DVC) planning. Donors should now be able to rely on the opinion to plan in a manner that substantially reduces the risk of unexpected gift and generation-skipping transfer (GST) taxes when transferring hard-to-value assets. Although other techniques using DVCs have been recognized prior to Wandry, all prior cases approving these transactions involved a ...

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