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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.

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.


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TAGS: Philanthropy
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