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Richard L. Fox, shareholder in Buchanan’s Tax section, wrote an article for the Planned Giving Design Center  titled, “Dieringer v. Commissioner: Estate Tax Charitable Deduction for Bequest of Stock to Private Foundation Limited to Post-Death Redemption Proceeds - A Flawed Result?”

“The United States Tax Court in Estate of Dieringer v. Commissioner, 146 T.C. – No. 8 (March 30, 2016), held that the decedent’s estate was allowed an estate tax charitable deduction for stock bequeathed to a private foundation equal only to amount of the proceeds received upon the redemption of the stock a few months after her death, and not the greater estate tax value reported in her United States Estate (and Generation-Skipping Transfer) Tax Return (Form 706).”