On November 18, 2011, the Department of the Treasury issued proposed regulations1 withdrawing the proposed regulations issued April 25, 20082 which were designed to combat post-death maneuvering of value in utilizing the alternate valuation date approach to federal estate tax valuation.3 The issue had arisen because of the strategy employed in Kohler, Jr. v. Commissioner4 by which a corporate reorganization after death was used to reduce the value of the estate from $144.5 million to $47 million.



To view the content in your browser, please download Adobe Reader or, alternately,
you may Download the file to your hard drive.

NOTE: The latest versions of Adobe Reader do not support viewing PDF files within Firefox on Mac OS and if you are using a modern (Intel) Mac, there is no official plugin for viewing PDF files within the browser window.