A Well-Intentioned Mistake: Revenue Procedure 2005-24A Well-Intentioned Mistake: Revenue Procedure 2005-24
Revenue Procedure 2005-241 published April 18, 2005 and effective as of March 30, 2005 is among the most controversial rulings promulgated by the Internal Revenue Service in recent memory. It has been roundly criticized by estate planners and their organizations for characterizing an innocuous fact pattern as problematic, for introducing new problems where none previously existed and for prescribing
Charles A. Redd, partner, Sonnenschein Nath & Rosenthal LLP, St. Louis
Revenue Procedure 2005-241 — published April 18, 2005 and effective as of March 30, 2005 — is among the most controversial rulings promulgated by the Internal Revenue Service in recent memory. It has been roundly criticized by estate planners and their organizations for characterizing an innocuous fact pattern as problematic, for introducing new problems where none previously existed and for prescribing an inadequate and unworkable procedure to avoid potentially draconian tax consequences.2 It is ironic that Rev. Proc. 2005-24 has generated such upheaval, given that the IRS crafted it in an apparently genuine effort to apprise the public of what the Service viewed as a...
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