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Not All Defined Value Clauses Are Equal, Wendy G. Gerzog
Not All Defined Value Clauses Are Equal, Wendy G. Gerzog
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Defined value clauses used to value nonmarketable family limited partnership (FLP) interests create valuation distortions and other public policy issues. This paper describes these abuses and proposes the employment of restrictions similar to those applied to pecuniary formula marital deduction clauses.
The article explains how pecuniary formula marital deduction provisions created valuation distortions by allowing for undervaluation of the marital share that were remedied by the IRS’s Rev. Proc. 64-19 and the enactment of section 2056(b)(10). The article analyzes recent case law expanding the use of defined value clauses into the FLP area and criticizes the courts for not applying …
Boomer-Ang Eldercare: Deductible Claim?, Wendy G. Gerzog
Boomer-Ang Eldercare: Deductible Claim?, Wendy G. Gerzog
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In this article, Gerzog discusses Estate of Olivo, in which the Tax Court determined the deductibility under section 2053 of a claim against the decedent’s estate for eldercare services provided by a family member.