Estate of Powell v. Commissioner1 is well-known among estate-planning professionals for having staked out new ground in its Internal Revenue Code Section 2036(a)(2) analysis. The decedent, Nancy Powell, a week before her death, conveyed about $10 million in cash and securities to a family limited partnership (FLP) in exchange for a 99% limited partner interest. The Tax Court held that IRC Section 2036(a)(2) applied because, at the moment of her death, the decedent had the
All access premium subscription
Please Log in if you are currently a Trusts & Estates subscriber.
If you are interested in becoming a subscriber with unlimited article access, please select Subscription Options below.
Questions about your account or how to access content?
Contact: [email protected]
