Professional press · cited in 3 of our stories.
Rev. Proc. 2026-25 treats contributions as present-interest gifts eligible for the $19,000 annual exclusion, but one extra gift or a Form 709 filed for another reason can undo the relief.
In Estate of Fields, the court upheld a $1.8 million estate tax deficiency and a negligence penalty, finding a Texas family limited partnership had no real purpose beyond an estate tax discount.
At the 60th Heckerling Institute, a leading panel warned that OBBBA's 2/37 itemized deduction haircut may reach trust distributions, as planning shifts from estate tax toward income tax.
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