Asset Restructure After Elder’s Fall Doesn’t Secure Tax Discount

The nephew of a late oil entrepreneur can’t rely on asset transfers he undertook as her health rapidly declined to justify a $6.2 million discount on her estate’s federal tax bill, the US Tax Court said Thursday.

When Anne Milner Fields fell in the presence of her caregiver, her great nephew Bryan Milner transferred most of her $17 million in personal assets to an entity he formed that month in 2016, AM Fields LP. Fields became its limited partner and got above a 99.99% interest, while Milner’s other business, AM Fields Management LLC, was general partner and received an interest ...