Thursday, September 2, 2004
The Third Circuit yesterday affirmed the Tax Court’s application of § 2036 to the pre-death transfer of $2.8 milllion of securities to two family limited partnerships in Estate of Thompson v. Commissioner, No. 03-3173 (3rd Cir. Sept. 1, 2004). Interestingly, 2 of the 3 judges on the panel filed a long concurring opinion.
