Fixing Crummey Problems

Fixing Crummey Problems

The Turner decision proves that a taxpayer can win a fight with the IRS over gifts of present interests


Ever since the U.S. Court of Appeals for the Ninth Circuit issued its Crummey v. Commissioner1 ruling in 1968, the Internal Revenue Service and taxpayers have been doing battle over which gifts to trusts are present interests that qualify for the annual exclusion from gift tax. Historically, taxpayers have won these

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