In PLR 201129033, the IRS ruled that a transfer of stock by a taxpayer and his spouse to a charity will be a transfer of the entire interest in the property, not a split interest under section 2522, and that the value of the gift is equal to the value of the gift tax charitable deduction.
Posted by Brian Spring, Associate Editor, Wealth Strategies Journal.
Posted by Brian Spring, Associate Editor, Wealth Strategies Journal.
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