Waiting for the Other Shoe

Last year in Estate of Dieringer v. Commissioner the Tax Court disallowed a large portion of a claimed estate tax charitable deduction for the transfer of the decedent's controlling interest in a closely-held stock to a private foundation, where the corporation redeemed the stock at a steep discount from its reported estate tax value. The logic of the decision is arguably flawed, and the 9th Circuit federal appeals court may reverse, but the executor's troubles may be far from over.