A Huge Taxpayer Win in Favor of Formula Clauses

A recent U.S. Tax Court case (Wandry v. Commissioner, T.C. Memo 2012-88, March 26, 2012) highlights the usefulness of formula clauses in gift transactions. The taxpayers, husband and wife, made gifts to their children and grandchildren of interests in a family limited liability company. Their tax attorney advised them to make all gifts as a …

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