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