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Sales Of Remainder Interests: Reconciling Gradow V. United States And Section 2702, Martha W. Jordan Dec 1994

Sales Of Remainder Interests: Reconciling Gradow V. United States And Section 2702, Martha W. Jordan

Martha W. Jordan

This article seeks to answer the question of whether the sale of a remainder interest for its actuarial value is exempt from transfer tax. Generally, when a taxpayer sells property for its fair market value, the taxpayer has been adequately compensated and, therefore, should not be subject to transfer tax. The sale of a remainder interest, however, raises various questions that are not present when property is sold outright. The sale of a remainder interest divides the underlying property into two split-interests: the remainder interest and the retained or present interest. The fair market value of split-interests is commonly determined …


Minority Discounts: The Alchemy In Estate And Gift Taxation, James R. Repetti Dec 1994

Minority Discounts: The Alchemy In Estate And Gift Taxation, James R. Repetti

James R. Repetti

[Also appears in Federal Wealth Transfer Tax Anthology, edited by Paul L. Caron, Grayson M.P. McCouch, Karen C. Burke, 269-275. Cincinnati: Anderson Publishing, 1998. An adaptation with title "The Alchemy in Estate and Gift Taxation" appears in Boston College Law School Magazine 4 (Spring 1996): 28-32.]


Commentary: Fixing Realization Accounting: Symmetry, Consistency And Correctness In The Taxation Of Financial Instruments, Diane M. Ring Dec 1994

Commentary: Fixing Realization Accounting: Symmetry, Consistency And Correctness In The Taxation Of Financial Instruments, Diane M. Ring

Diane M. Ring

No abstract provided.