Atkinson Lessons

The implications of a case handed two years ago have not been adequately appreciated by practitioners. The Court of Appeals for the Eleventh Circuit on Oct. 16, 2002, affirmed a decision of the Tax Court denying an estate tax deduction for a charitable remainder annuity trust (CRAT) that had not been administered according to the terms of a trust. In Atkinson v. Comm'r,1 the Eleventh Ciruit showed

The implications of a case handed two years ago have not been adequately appreciated by practitioners.

The Court of Appeals for the Eleventh Circuit on Oct. 16, 2002, affirmed a decision of the Tax Court denying an estate tax deduction for a charitable remainder annuity trust (CRAT) that had not been administered according to the terms of a trust. In Atkinson v. Comm'r,1 the Eleventh Ciruit showed that the courts, as well as the Internal Revenue Service, will require

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