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Check-The-Box Regs And Gift Tax Discounts, Wendy G. Gerzog
Check-The-Box Regs And Gift Tax Discounts, Wendy G. Gerzog
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This article discusses the recent Tax Court decision in Pierre and the effect for gift tax purposes of an entity’s classification made under the check-the-box regulations. The court was split on what those regulations mean when they state that an entity is to be disregarded ‘‘for federal tax purposes.’’