The Waiting Game 2011-01-01The Waiting Game 2011-01-01

Radd L. Riebe

Waiting for Godot is a classic play in which the protagonists await the arrival of a mysterious problem solver who never arrives. For estate planners and valuation professionals, 2010 was similarly a time for waiting — for tax law resolutions, for the economy to take off and for clarity on valuation controversies. We're still waiting for the last two.

Several significant valuation issues were the subjects of cases in 2010, although the issues remain far from settled. The appropriate treatment of built-in gains (BIG), what disqualifies partnership and limited liability company interests from annual exclusion gifts, the ongoing saga of Internal Revenue Code Section 2036¹ estate inclusion and modified carryover basis were among ...