Wendy C. Gerzog (Baltimore) has posted Check-the-Box Regs and Gift Tax Discounts, 126 Tax Notes 871 (Feb. 15, 2010), on SSRN. Here is the abstract:
This article discusses the recent Tax Court decision in Pierre [v. Commissioner, 133 T.C. No. 2 (2009)] and the effect for gift tax purposes of an entity’s classification made under the check-the-box regulations. The court was split on what those regulations mean when they state that an entity is to be disregarded ‘‘for federal tax purposes.’’
