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- Title
Dot All 'I's and Gross All T's: Estate of Tamulis v. Commissioner and the Narrowing of the Substantial Compliance Doctrine to the Technical Compliance Doctrine.
- Authors
Chouest, Hanna M.
- Abstract
The article focuses on charitable remainder trusts with reference to the Estate of Tamulis v. Commissioner court case in the U.S. In the case, judge for the Seventh Circuit refused to apply the substantial compliance doctrine to a taxpayer's estate that failed to comply with all of the requirements of section 664 to create a charitable remainder trust. It is stated that the Seventh Circuit correctly held that the charitable remainder trust established by the Tamulis estate did not satisfy the requirements of the substantial compliance doctrine as it has been applied by the courts. It is stated that the judge did not take the opportunity made available to him in Tamulis to clarify the doctrine.
- Subjects
UNITED States; CHARITABLE uses, trusts, &; foundations; ACTIONS &; defenses (Law); CHARITY laws &; legislation; TAXATION; JUDGES; PUBLIC finance; TRUSTS &; trustees; JURISTIC persons
- Publication
Tax Lawyer, 2008, Vol 62, Issue 1, p259
- ISSN
0040-005X
- Publication type
Article