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Tax: Estate of Stewart v. Commissioner of Internal Revenue

U.S. Court of Appeals, Second Circuit Tax Lifetime Gifts — Transferor’s Retained Possession Estate of Stewart v. Commissioner of Internal Revenue 07-5370-ag Appealed from the U.S. Tax Court Background: Decedent, Margot Stewart, gave a 49 percent share of a mixed-use building to her son, Brandon Stewart. Upon Margot’s death, the IRS sought to include the gift in her gross estate under ...