Tax Law Update

Second Circuit vacates Tax Court's determination on inclusion of transferred interest in real estate under IRC Section 2036 — In Estate of Stewart v. Commissioner, No. 07-5370, (2d. Cir. Aug. 9, 2010), the majority of the U.S. Court of Appeals for the Second Circuit agreed with the Tax Court that an implied agreement existed between the decedent, Margot, and her son, Brandon, that triggered inclusion of a portion of a transferred interest in a Manhattan brownstone in