Skip navigation
TE-philanthropy.jpg

Nelson v. Commissioner: Inadequate Drafting Blows The “Lid” Off Transfer Taxes

Christopher P. Woehrle discusses the charitable lid technique and why it’s an effective tool for the estate and charitable gift planner.
Resources

In James C. Nelson v. Commissioner,1 a donor transferred limited partnership (LP) interests equal to percentage interests that were calculated by an appraiser following a gift and a sale to a trust. The LP’s primary asset was common stock of a family-owned holding company. The holding company owned 100% of seven operating subsidiaries.

All access premium subscription

Please Log in if you are currently a Trusts & Estates subscriber.


If you are interested in becoming a subscriber with unlimited article access, please select Subscription Options below.


Questions about your account or how to access content?


Contact: [email protected]

TAGS: Philanthropy
Hide comments

Comments

  • Allowed HTML tags: <em> <strong> <blockquote> <br> <p>

Plain text

  • No HTML tags allowed.
  • Web page addresses and e-mail addresses turn into links automatically.
  • Lines and paragraphs break automatically.
Publish