Estate Fights $5.4 Million Tax Liability Over Trust Distribution

An estate is challenging IRS’ determinations resulting in a $5.3 million estate tax liability for a real estate businesswoman.

The IRS assessed the deficiency against the estate of Theresa P. Brosnan, who died in October of 2020 after revising upward the tax liability of 11 California properties where Brosnan had reported a fractional interest on a Schedule F filing.

It also determined a liability arising from a trust she had created with her predeceased spouse, John Brosnan.

According to the estate’s petition, the dispute arises over some language of the trust the couple had formed, with the estate reporting its ...