Estate of Dorothy Brown v. Commissioner of Internal Revenue (U.S. Tax Court)

The U.S. Tax Court is charged with determining, amongst other things, whether the transfer of some of Dorothy Brown’s interest in a living trust into two other trusts in the year 2004 and receiving a subsequent interest in those trusts was deficiently valued. Commissioner sought a summary judgment on this issue but the Court determined that due to the disputed nature of material facts, this could not be decided.