Section 2036 Estate Controversies of Tenants in Common Interests

For estate tax purposes, Internal Revenue Code Section 2036(a) includes in a decedent's gross estate the value of certain property transferred during life.1 IRC Section 2036 generally applies when a taxpayer retains rights to the property transferred, the property's income2 or the right to designate others who can receive the rights to the property or its income.3 The Internal Revenue Service frequently