The IRS and executors have settled two cases in the United States Tax Court involving members of the Woelbing family, which owns Carma Laboratories Inc. of Franklin, Wisconsin, the maker of Carmex skin care products, and a sale of Carma stock to an irrevocable trust in 2006 that relied on a “defined value clause.” The agreed dispositions of the Tax Court cases indicate that the IRS conceded all the additional taxes and penalties it had previously asserted. But the end of this litigation still leaves questions and, perhaps, even warnings for estate planning clients and their advisers.
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Estate Tax CounselMr. Blumenfeld concentrates his practice in the areas of International Tax and Estate Planning, Probate Law, and Representation of Resident and Non-Resident Aliens before the IRS.
Prior to joining Marini & Associates, P.A., he spent 32 years as the Senior Attorney with the Internal Revenue Service (IRS), Office of Deputy Commissioner, International.
While with the IRS, he examined approximately 2,000 Estate Tax Returns and litigated various international and tax issues associated with these returns.As a result of his experience, he has extensive knowledge of the issues associated with and the preparation of U.S. Estate Tax Returns for Resident and Non-Resident Aliens, Gift Tax Returns, Form 706QDT and Qualified Domestic Trusts.