Document Deficiency

The July 12 decision in Senda v. Commissioner1 is another prime example of how taxpayer abuses lead to Internal Revenue Service victories. Certainly, the recent string of formidable IRS wins concerning Internal Revenue Code Sections 2036 and 2503 has helped astute estate planners put together a list of do's and don'ts. Now, Senda does for IRC Section 2511 (indirect gifts) what Strangi2 and Hackl 3

Carsten Hoffmann | Sep 01, 2004

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The July 12 decision in Senda v. Commissioner¹ is another prime example of how taxpayer abuses lead to Internal Revenue Service victories. Certainly, the recent string of formidable IRS wins concerning Internal Revenue Code Sections 2036 and 2503 has helped astute estate planners put together a list of do's and don'ts. Now, Senda does for IRC Section 2511 (indirect gifts) what Strangi² and Hackl ³ did for Sections 2036 and 2503,

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