Cahill, Powell and the Ongoing Evolution Of IRC Section 2036(a)(2)

In Estate of Richard E. Cahill, et al. v. Commissioner,¹ the Tax Court denied partial summary judgment to an estate that contested a deficiency notice in which the Internal Revenue Service adjusted the value of the decedent’s rights in three split-dollar life insurance arrangements from $183,700 to more than $9.61 million. The court declined to grant partial summary judgment on the estate’s arguments that Internal Revenue Code Sections 2036, 2038 and 2703 didn