... More on Letts.In the previous item, it is fairly easy to see how the Tax Court could apply the consistency rule to the economic unit of the Letts family which, the court said, had "sufficient identity of interests." However, the results are much more uncertain in applying the consistency rule when the facts diverge significantly from those in Letts. To avoid the need by either the IRS An abbreviation for the Internal Revenue Service, a federal agency charged with the responsibility of administering and enforcing internal revenue laws. or the courts to repeatedly interpret the consistency rule in future cases, the President's 1999 Budget Plan proposes to amend Sec. 2044. The amendment would provide that, if a marital deduction marital deduction n. when one spouse dies, the survivor may take a tax deduction of half of the value of the estate of the dying spouse. Thus, the minimum value of the estate before there is a possible federal estate tax rises from $600,000 to $1,200,000 at the death is allowed with respect to QTIP QTIP Qualified Terminable Interest Property QTIP Quit Taking It Personally QTIP Quantum Theory Integral Package property under Sec. 2523(f) or 2056(b)(7), inclusion is required in the surviving spouse's estate under Sec. 2044. In the meantime Adv. 1. in the meantime - during the intervening time; "meanwhile I will not think about the problem"; "meantime he was attentive to his other interests"; "in the meantime the police were notified" meantime, meanwhile , until the proposed legislation is passed, taxpayers may find that planning opportunities continue to exist when it can be argued that the parties do not display sufficient identity of economic interests to be required to abide by To stand to; to adhere; to maintain. See also: Abide the duty of consistency. |
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