A Well-Intentioned Mistake: Revenue Procedure 2005-24

Revenue Procedure 2005-241 published April 18, 2005 and effective as of March 30, 2005 is among the most controversial rulings promulgated by the Internal Revenue Service in recent memory. It has been roundly criticized by estate planners and their organizations for characterizing an innocuous fact pattern as problematic, for introducing new problems where none previously existed and for prescribing

Revenue Procedure 2005-241 — published April 18, 2005 and effective as of March 30, 2005 — is among the most controversial rulings promulgated by the Internal Revenue Service in recent memory. It has been roundly criticized by estate planners and their organizations for characterizing an innocuous fact pattern as problematic, for introducing new problems where none previously existed and for prescribing an inadequate and unworkable procedure to avoid potentially draconian tax conse

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