Christiansen v. Comm'r of Int'l. Rev., No. 08-3844
In the IRS's appeal from the tax court's determination that a partial disclaimer was valid as to an amount that subsequently passed to a foundation that the decedent named as a contingent beneficiary in her will, the order is affirmed where 1) Treasury Regulation section 20.2055-2(b)(1) did not speak in terms of the existence or finality of an accounting valuation at the date of death or disclaimer; and 2) the court of appeals could find no evidence of a clear Congressional intent suggesting a policy to maximize incentives for the Commissioner to challenge or audit returns.
Read Christiansen v. Comm'r of Int'l. Rev., No. 08-3844
Submitted: September 22, 2009
Filed: November 13, 2009
Opinion by Judge Melloy
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