""Life Estate"" — Epstein Files Search

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EFTA01204564Set 9

2014-08-3132p8,473w

applicable actuarial tables promulgated by the Internal Revenue Service for use in valuing life estates and remainders, will be: Life Tenant — 32.867% Remainderman — 67.133% WHEREAS, if settlement on the purchase ... death of the Life Tenant. The aforesaid period is hereinafter referred to as the "Life Estate Period." (A) During the Life Estate Period, the Life Tenant shall be entitled ... Tenant shall not be sold, commuted or prepaid by any person. (B) During the Life Estate Period, property held under this Agreement, including any share thereof held under Clause SECOND

https://www.justice.gov/epstein/files/DataSet%209/EFTA01204564.pdf

EFTA00584335Set 9

Split-Interest Purchase: Comparison of Single Life Estate and Successive Life Estates Siu le Life Estate Successive Life Estates Share of Purchase Life Interest: 32.867% Life Interests: 42.290% Price (allocation ... actuarially Trust: 67.133% determined) Trust: 57.710% Advantages • Residence is encumbered by life estate for shorter • Reduces share of purchase price borne by trust period • DRB's right to continue ... residence subject to • Determining share of purchase price borne by each Trustee determination successive life estate may require retaining an actuary • DRB must pay for her interest using independent funds

https://www.justice.gov/epstein/files/DataSet%209/EFTA00584335.pdf

EFTA01131014Set 9

2012-05-1129p14,282w

time is considered a partial interest. • For example, a donor cannot retain a life estate and contribute the remainder interest in a work of art to charity and receive ... tenant in common interest in a painting), but not horizontal divisions (i.e., a retained life estate 16 IRC Section 170(b)(1)(C)(iii). -7- Venable LLP 575 7th Street

https://www.justice.gov/epstein/files/DataSet%209/EFTA01131014.pdf

EFTA01097356Set 9

concludes that under the circumstances the donor made a transfer with a retained life estate under I.R.C. §2036. This TAM in the view of some is poorly reasoned and, perhaps ... purported to be a split purchase with a trust, with the taxpayer acquiring a life estate and the trust acquiring the reminder interest in a general partnership interest

https://www.justice.gov/epstein/files/DataSet%209/EFTA01097356.pdf

EFTA01252591Set 9

Owners in person or by proxy, except that the holder or holders of a life estate in a Unit shall have the sole right to cast the votes allocated ... Unit. If more than one of the joint Owners vote or more than one life estate holder in a Unit vote, the unanimous action of all joint Owners or joint ... life estate holders voting shall be necessary to effectively cast the votes allocated to the particular Unit. Such unanimous action shall be conclusively presumed if any one of such multiple

https://www.justice.gov/epstein/files/DataSet%209/EFTA01252591.pdf

EFTA00607791Set 9

2014-06-185p2,790w

Documents > PLRs/TAMs/CCAs and Other Advice > 2014 > PLR 201442046 - Section 2036 - Transfers With Retained Life Estate PLR 201442046 - Section 2036 - Transfers With Retained Life Estate Internal Revenue Service Department

https://www.justice.gov/epstein/files/DataSet%209/EFTA00607791.pdf

EFTA01126625Set 9

2006-10-20210p79,660w

Code Section 2036(a) contains the general rule for "transfers with a retained life estate" as follows: The value of the gross estate shall include the value of all property ... property or the income therefrom. B. Treasury Regulations Section 20.2036-1, transfers with retained life estate, is instructive. It states, in relevant part, the following: 1. A decedent's gross

https://www.justice.gov/epstein/files/DataSet%209/EFTA01126625.pdf

EFTA01104587Set 9

because as of the date of her death, Carol's interest was only a life estate. EPTL §10-6.6 says that a trustee who has absolute discretion under the terms

https://www.justice.gov/epstein/files/DataSet%209/EFTA01104587.pdf

EFTA00993062Set 9

2014-07-022p563w

Clapp ffi wrote: Jeffrey, The Trustees are still debating the single vs. successive life estates for the townhouse purchase. What are your thoughts about preferring the single life estate

https://www.justice.gov/epstein/files/DataSet%209/EFTA00993062.pdf

EFTA01918981Set 10

2014-07-022p247w

Split-interest property purchase Jeffrey, The Trustees are still debating the single vs. successive life estates for the townhouse purchase. What are your thoughts about preferring the single life estate

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01918981.pdf

EFTA01919178Set 10

2014-07-022p354w

Clapp wrote: Jeffrey, The Trustees are still debating the single vs. successive life estates for the townhouse purchase. What are your thoughts about preferring the single life estate? Ada Clapp

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01919178.pdf

EFTA00991366Set 9

2014-06-053p700w

would be a good fit here. It works as follows: Leon would purchase a life estate directly from the seller and the trust would purchase the remainder interest directly from ... either-so maybe not a downside). ■ Leon would have to own the life estate individually and not in an entity (the trust could acquire the remainder interest

https://www.justice.gov/epstein/files/DataSet%209/EFTA00991366.pdf

EFTA00991373Set 9

2014-06-053p731w

would be a good fit here. It works as follows: Leon would purchase a life estate directly from the seller and the trust would purchase the remainder interest directly from ... either-so maybe not a downside). ■ Leon would have to own the life estate individually and not in an entity (the trust could acquire the remainder interest

https://www.justice.gov/epstein/files/DataSet%209/EFTA00991373.pdf

EFTA00803858Set 9

2018-08-231p582w

DEEDS OTHER contd RELEASE OF VI TAX LIENS contd GIFT WITH RESERVATiON OF LIFE ESTATE. 76,613.19; 32,608.63 Marjorie A King to Judith L Hobson & Marjorie King Cecil George ... Life Estate Interest on 33-16 Nadir 150,000 Paul A David & Katherine Schultz. 87,928.75 CONDO DEED. David L & Maureen T Swink to Luna Wheatley

https://www.justice.gov/epstein/files/DataSet%209/EFTA00803858.pdf

EFTA01193830Set 9

Trust (Remainder Interest: 57.710%) $27,700,800 Advantages • Residence is encumbered by life estate for shorter period • Reduces share of purchase price borne by trust • Additional planning flexibility after ... residence is in improvement costs) borne by each successive life estate the Trustees' discretion. may require retaining an actuary (for each expenditure) • Trustees can charge rent, which is a "gift

https://www.justice.gov/epstein/files/DataSet%209/EFTA01193830.pdf

EFTA01078478Set 9

2014-06-1731p13,124w

granted the right to assign the Contract to one or more individuals (as a life estate or otherwise) and/or to a limited liability company, trust, corporation, or other entity ... granted the right to assign the Contract to one or more individuals (as a life estate or otherwise) and/or to a limited liability company, trust, corporation, or other entity

https://www.justice.gov/epstein/files/DataSet%209/EFTA01078478.pdf

EFTA01103666Set 9

time of decedent's death, unless otherwise noted. 2 SEC. 2036. TRANSFERS WITH RETAINED LIFE ESTATE. (a) GENERAL RULE.— The value of the gross estate shall include the value

https://www.justice.gov/epstein/files/DataSet%209/EFTA01103666.pdf

EFTA00811439Set 9

testifying in a criminal trial, a (C) The wife's new husband has a life estate in the witness must be able to see the defendant." The state land

https://www.justice.gov/epstein/files/DataSet%209/EFTA00811439.pdf

EFTA02375921Set 11

2014-07-032p876w

taxpayers to whom they are issued) wher= the IRS approved structures involving two life estates where all term int=rest holders EFTA_R1_01384796 EFTA02375921 acquired their interest with separate

https://www.justice.gov/epstein/files/DataSet%2011/EFTA02375921.pdf

EFTA00598147Set 9

2011-06-158p5,152w

EFTA00598153 There, a taxpayer assigned his interest in two trusts subject to the life estate of his mother. The taxpayer instructed the trustees that, upon his mother's death, certain

https://www.justice.gov/epstein/files/DataSet%209/EFTA00598147.pdf

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Corpus: 1990-03-17 – 2025-12-01

August 2014

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Results by Dataset29 total

Set 9

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Set 10

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Set 11

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