In Marion Levine v. Commr. 158 T.C., a resounding victory was recently given to a taxpayer who pursued what many view as an aggressive spit-dollar life insurance plan for the purpose of minimizing estate taxes. This CLE course will explain the case and split-dollar planning as well as review prior cases that were decided against other taxpayers who used similar techniques.

The course will explain what the taxpayer did right in the Levine case, the mistakes made in prior cases and how a review of such cases, such as Estate of Cahill, can be used to guide taxpayers considering such planning. The course will identify steps that the Levine court found favorable, how to implement a similar plan as well as how it can be applied to almost any type of estate planning and other broad applicability.

The IRS arguments and Tax Court’s response regarding sections 2036,2038 and 2703 will also be presented.