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The Appeal Of ChristiansenThe Appeal Of Christiansen
The Internal Revenue Service has appealed Christiansen an important legal victory for taxpayers trying to do charitable lid planning. Just-filed briefs give a glimpse of both sides' arguments. Christiansen v. Commissioner, 2009 WL 789131, case identification number 08-3844 (8th Cir. 2009). Estate of Christiansen v. Commissioner, 130 T.C. No. 1 (Jan. 24, 2008) blessed the ability of a taxpayer to establish
David T. Leibell and Daniel L. Daniels, partners in the Stamford, Conn., office of Wiggin and Dana LLP
The Internal Revenue Service has appealed Christiansen — an important legal victory for taxpayers trying to do “charitable lid” planning. Just-filed briefs give a glimpse of both sides' arguments. Christiansen v. Commissioner, 2009 WL 789131, case identification number 08-3844 (8th Cir. 2009).
Estate of Christiansen v. Commissioner, 130 T.C. No. 1 (Jan. 24, 2008) blessed the ability of a taxpayer to establish a “charitable lid” estate plan activated by disclaimer. A charitable lid is an estate plan in which a testator leaves a set dollar amount of his estate to his children with the residuary estate passing to a charitable organization. T...
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