We have written before the importance of a property prepared Form 706 Estate (and Generation Skipping Transfer) Tax Return (“706”)[1] as well as the importance of a properly prepared Form 709 Gift Tax Return[2]. In our prior article discussing the 706, we highlighted a Private Letter Ruling (“PLR”) in which the Estate was granted a…
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In a recent case out of the Tax Court, a surviving spouse’s Estate was denied the portability of the Deceased Spouse’s Unused Exclusion (“DSUE”) from the decedent’s spouse who had passed away two years before the survivor.[1] The Estate Tax Return (“706”) for the decedent’s spouse, while filed, was not “complete and properly prepared” and…
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In a prior article, I wrote about the importance of properly prepared Form 706 Estate Tax Return, discussing a Private Letter Ruling (“PLR”) that highlighted some common mistakes made on the Form 706.[1] In that article, I discussed issues related to the marital deduction and the allocation of a decedent’s unused Generation Skipping Transfer Tax…
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