Eliminating The Irs s Requisition For Summary Judgment

In eliminating the IRS s requisition for summary judgment in the case, the Tax Reckoning stated that it would no longer follow its opinion in McCord, in which it had held that in advance of the death of a person, no recognized method exists for approximating the burden of the estate tax with a sufficient degree of certitude to be effective for Federal gift tax purposes (McCord, 120 T.C. at 402). Therefore, under McCord, no discount would be allowed on a gift tax return for a potential estate tax liability. The Tax Court, however, now found that its holding in McCord was wrongly decided. It observed that determining the amount of an estate tax that may be in effect when the taxpayer dies is no more speculative than determining the amount of capital gains tax that should be applied to reduce the value of stock in an estate and that the Tax Court and many other courts had held that the value of stock for gift or estate tax purposes should be reduced by capital gains tax. 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