Zan Zwang, a widower, died September 4, 2013, and was survived by his three adult children. On

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Zan Zwang, a widower, died September 4, 2013, and was survived by his three adult children. On September 4, 2010, he gave each child stock valued at $2 million and paid gift tax with the return he filed in 2011. Exclusive of any gross-up, Zwang's gross estate is valued at $6.2 million. You are preparing Zwang's estate tax return, and your manager advises you that she seems to recollect reading a technical advice memo addressing when the three-year period begins in this context. Prepare a memo to your manager in which you address when the three-year period begins and, thus, whether Zwang's gross estate must include a gross-up for the taxes on the 2010 gift.
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Federal Taxation 2014 Comprehensive

ISBN: 9780133438598

27th Edition

Authors: Timothy J. Rupert, Thomas R. Pope, Kenneth E. Anderson

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