The Service has issued proposed regulations (REG-115781-01) that would amend the regulations under sections 170, 2055, and 2522 governing charitable guaranteed annuity interests and unitrust interests. The proposed regs would conform the income, gift, and estate tax regs to the Tax Court's decision in Estate of Boeshore v. Commissioner, 78 T.C. 523 (1982), which held that portions of section 20.2055-2(e)(2)(vi)(e) of the Estate Tax Regulations were invalid.
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