Back in November we wrote up the Tax Court decision in Dickinson for the Jack Straw, focusing on the argument IRS was actually making, which was not made all that clear in the text of the opinion. Still mystified why IRS did not take an appeal.

Phil Purcell over at PG Today asked me to turn this into an article for that publication. Linked below are the text as submitted and as it appeared in print.

Also linked is the slide deck I used on a joint presentation with Kate Crary at Gadsden Schneider & Woodward for the charitable planning and orgs group of the RPTE section of the ABA.

That deck has since been expanded to include a discussion of the pending litigation in Fairbairn v. Fidelity Charitable. We will be using a version of that deck in a webinar I am co-presenting tomorrow and again on Thursday with Bryan Clontz at Charitable Solutions, LLC.

A couple of years ago I threw together a webinar for Lorman on planning for intergenerational transfer of a vacation home. This was an orphaned topic for them, created years earlier by someone who had moved on to other projects. But they wanted to repeat it, and somehow they found me.

And obviously it is not within my usual scope. My skillset, yes, but not my wheelhouse. Or whatever is the jargon.

But I did it, and learned a thing or two along the way about qualifying the transfer of a nonvoting interest in a family limited partnership for the gift tax annual exclusion.

And then more recently the folks at WealthCounsel picked up on it and asked me to flesh this out into an article for their quarterly. Which just came out today. Enjoy.