An oil entrepreneur’s estate failed to show that a transfer of assets into a limited partnership shortly before her death was motivated by non-tax purposes, a federal appeals court ruled Monday.
The full $17 million in assets transferred by Anne Milner Fields’ great-nephew and agent, Bryan Milner into AM Fields LP must be included in Fields’ gross estate under IRC Section 2036(a), the US Court of Appeals for the Fifth Circuit said, affirming the US Tax Court’s 2024 ruling.
Milner argued the financial moves were taken for significant and legitimate non-tax-related reasons: to resolve limitations of Fields’ ...