In the Estate of Miriam Warne, T.C. Memo 2021-17, Tax Court Judge Buch determined the estate and gift tax values of limited liability companies (LLCs) that held ground leases in several properties.
The decedent and her predeceased husband created a Family Trust that became the majority interest holder of five LLCs. In 2012, the decedent gave interests in each of the LLCs to her two sons and three grandddaughters. At her death, the decedent transferred 75 percent of her interest in one of the LLCs (LLC 5) to a family charitable foundation and the remaining 25 percent to a church. On the estate tax return, the estate deducted the full value of the 100 percent interest in LLC 5 that was shown on the return.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.