• Private annuity transaction deemed sale of interest in QTIP trusts under Internal Revenue Code Sec-
tion 2519—In Estate of Virginia Kite v. Commissioner,
T.C. Memo. 2013-43 (Feb. 7, 2013), the Tax Court addressed the tax consequences of a series of transactions involving marital trusts for the benefit of Virginia Kite. Three trusts were at issue. The first was a qualified terminable interest property (QT
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