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Lessons From Levine and the Not-So-Illusory Fiduciary

The latest tale in the application of IRC Section 2036(a)(2).

The Tax Court’s recent decision in Estate of Levine v. Commissioner1 provides useful taxpayer-friendly guidance. Although Internal Revenue Code Section 2036 has been part of the IRC for over 90 years, arguments and holdings regarding its application continue to evolve. The Internal Revenue Service’s longstanding position is that this provision applies broadly. The IRS continually refines, reforms and reasserts arguments seeking to use this provision to include

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