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An Attack On The Optimum Marital Deduction: Revenue Ruling 76-176, J. Rodney Johnson

Law Faculty Publications

A recent development in the field of estate and gift taxation-the issuance of Revenue Ruling 76-156 may be an indication of a policy decision on the part of the Internal Revenue Service to clamp down on the increasing utilization of the estate planner's most flexible tool in the ·area of post-mortem estate planning-the disclaimer. Due to the potential importance of this ruling, it seems desirable ( 1 ) to deal with the ruling, itself, in some detail, ( 2) to see how the ruling might affect an estate planning concept suggested in these pages last year, and ( 3) to …