Wendy C. Gerzog

University of Baltimore - School of Law

Professor

1420 N. Charles Street

Baltimore, MD 21218

United States

SCHOLARLY PAPERS

92

DOWNLOADS
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in Total Papers Downloads

13,385

CITATIONS

6

Scholarly Papers (92)

1.

Erickson: A Primer on FLPS

Tax Notes, Vol. 116, No. 3, 2007
Number of pages: 4 Posted: 21 Jul 2007
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 599 (43,724)

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family limited partnership, FLP, estate planning, estate tax, section 2036, Erickson, valuation, discount, bona fide sales

2.

Valuing Art in an Estate

Tax Notes, Vol. 117, No. 6, 2007
Number of pages: 6 Posted: 08 Nov 2007
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 430 (66,341)

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estate tax. valuation, art collection, paintings, fractional interest discount, IRS Art Panel

3.

Excluding Expert Valuation Testimony

Tax Notes, Vol. 132, No. 13, 2011
Number of pages: 3 Posted: 26 Sep 2011
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 427 (66,902)

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expert testimony, valuation, Boltar, Daubert, conservation easement, charitable deduction

4.

Linton Family LLC and the Step Transaction Doctrine

Tax Notes, Vol. 125, No. 9, 2009
Number of pages: 4 Posted: 02 Dec 2009
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 387 (75,237)

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Family LLC, indirect gift, nonmarketability discount, step transaction doctrine, Linton

5.

Hurford: FLP Practice Pointers

Tax Notes, Vol. 122, No. 6, 2009
Number of pages: 6 Posted: 11 Feb 2009 Last Revised: 23 Feb 2009
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 349 (84,769)

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family limited partnership, FLP, private annuity, Hurford, gift tax, estate tax, estate planning

6.

Linton Reversed: Indirect Gift and the Step Transaction Doctrine

Tax Notes, Vol. 130, No. 13, 2011
Number of pages: 5 Posted: 05 Apr 2011
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 341 (87,062)

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gift tax, FLP, family limited partnership, step transaction, indirect gift, Linton

7.

Equitable Apportionment: Recent Cases and Continuing Trends

Real Property, Probate and Trust Journal ABA, Vol. 41, p. 671, Winter 2007
Number of pages: 71 Posted: 01 Apr 2007
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 289 (104,418)

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equitable apportionment, estate planning, estate taxes, trusts, wills

8.

Miller: Effective FLP Line Drawing

Tax Notes, Vol. 124, No. 12, 2009
Number of pages: 4 Posted: 12 Oct 2009
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 275 (110,113)

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FLP, family limited partnership, estate tax, Miller, section 2036, bona fide sales exception, discounts

9.

The New Super-Charged PAT (Power of Appointment Trust)

Houston Law Review, Forthcoming, University of Baltimore School of Law Legal Studies Research Paper No. 2011-9
Number of pages: 34 Posted: 07 May 2011 Last Revised: 30 Aug 2011
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 274 (110,546)

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QTIP, Power of Appointment Trust, Marital Deduction, estate tax, gift tax, estate planning, reverse QTIP, bypass trust, state-only QTIP

10.

FLP Loss, but Crummey Win

Tax Notes, Vol. 133, No. 9, 2011
Number of pages: 5 Posted: 29 Nov 2011
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 265 (114,430)

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11.

Wimmer Wins FLP Annual Exclusions

Tax Notes, Vol. 138, No. 4, 2013
Number of pages: 5 Posted: 29 Jan 2013
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 257 (118,129)

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gift tax, family limited partnership, FLP, annual exclusion, trust, Wimmer

12.

Not All Defined Value Clauses are Equal

Pittsburgh Tax Review, Forthcoming
Number of pages: 45 Posted: 15 Jul 2012 Last Revised: 27 Aug 2012
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 254 (119,630)

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defined value clauses, valuation, gift tax, estate tax, marital deduction, charitable deduction, Procter, Robinette, tax and public policy

13.

Families for Tax Purposes: What About the Steps?

University of Michigan Journal of Law Reform, Forthcoming, University of Baltimore School of Law Legal Studies Research Paper No. 2008-03
Number of pages: 43 Posted: 03 Apr 2008 Last Revised: 31 Jul 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 254 (119,630)

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definition of family, stepchild, stepparent, income tax, estate and gift tax, corporate tax

14.

The Strict Rules of Charitable Split Interest Gifts

Tax Notes, Vol. 118, No. 5, 2008, University of Baltimore School of Law Legal Studies Research Paper No. 2008-08
Number of pages: 5 Posted: 29 Jan 2008 Last Revised: 15 Jun 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 247 (123,042)

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charitable deduction, split interest charitable gift, substantial compliance, estate tax, Tamulis

15.

Defined Value Clauses and Fair Market Value

Tax Notes, Vol. 134, No. 13, p. 1685, March 2012, University of Baltimore School of Law Legal Studies Research Paper
Number of pages: 4 Posted: 27 Mar 2012
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 241 (126,190)

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defined value clause, family LLC, FLP, fair market value, gift tax, Hendrix, Procter, McCord, charitable gift, American Bar Endowment

16.

From the Greedy to the Needy

Oregon Law Review, Forthcoming, University of Baltimore School of Law Legal Studies Research Paper No. 2009-05
Number of pages: 51 Posted: 16 Sep 2008 Last Revised: 11 Jan 2009
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 241 (126,190)

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charitable deduction, quid pro quo, public benefit, CLT, American Bar Endowment, McCord, conditional gift, donor advised funds, private foundation, income tax, gift tax

17.

Valuation Discounting Techniques: Terms Gone Awry

Tax Lawyer, Vol. 61, No. 3, 2008, University of Baltimore School of Law Legal Studies Research Paper No. 2009-16
Number of pages: 33 Posted: 20 Oct 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 240 (126,727)

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valuation, fair market value, family limited partnership, FLP, estate tax, gift tax, section 2031

18.

Holman: The FLP's New Clothes

Tax Notes, Vol. 120, No. 12, 2008
Number of pages: 6 Posted: 22 Sep 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 234 (129,952)

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Holman, FLP, family limited partnerships, valuation, indirect gift, section 2703, Shepherd, Senda, Amlie

19.

Tax Court FLP Confusion: Mirowski

Tax Notes, Vol. 120, No. 3, 2008
Number of pages: 4 Posted: 22 Jul 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 233 (130,497)

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family limited partnership, FLP, Mirowski, section 2036, Bongard test, estate tax, gift tax

20.

Check-the-Box Regs and Gift Tax Discounts

Tax Notes, Vol. 126, No. 7, 2010
Number of pages: 5 Posted: 17 Feb 2010 Last Revised: 26 Feb 2010
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 230 (132,127)

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FLP, family limited partnership, Pierre, check-the-box, lack of marketability discount, minority discount, gift tax

21.

Wandering Far Afield with Defined Value Clauses

Tax Notes, Vol. 135, No. 9, 2012
Number of pages: 6 Posted: 02 Jun 2012
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 216 (140,507)

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Defined Value Clauses, gift tax, family LLC, FLP, Wandry, Procter, Robinette

22.

College Savings Plans: Not Just for Education

Tax Notes, Vol. 122, No. 10, 2009
Number of pages: 4 Posted: 11 Mar 2009
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 209 (144,902)

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college savings plans, college savings accounts, section 529, income tax, gift tax, estate tax, tax avoidance, tax abuse

23.

Dealing with Postdeath Events

Tax Notes, Vol. 116, 2007
Number of pages: 6 Posted: 08 Nov 2007
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 209 (144,902)

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postdeath events, proposed regulations, estate tax, deduction under section 2053, claims against the estate

24.

Portability of Exemptions

Tax Notes, Vol. 119, No. 5, 2008
Number of pages: 4 Posted: 05 May 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 193 (156,124)

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portability, estate tax, exemptions, bypass trust, credit shelter trust, marital deduction, generation skipping transfer tax

25.

Mccord and Post-Gift Events

Tax Notes, Vol. 113, p. 349, October 23, 2006
Number of pages: 7 Posted: 25 Oct 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 188 (159,912)

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McCord, FLP, defined value clause, postgift events, valuation

26.

Rector and Gore: Two Recent FLP Cases

Tax Notes, Vol. 118, No. 10, 2008
Number of pages: 3 Posted: 04 Mar 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 187 (160,673)

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family limited partnership, FLP, estate planning, estate tax, section 2036, Gore, Rector, valuation, discount, bona fide sales

27.

Jorgensen: A Familiar FLP Story

Tax Notes, Vol. 124, No. 1, 2009
Number of pages: 4 Posted: 06 Jul 2009
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 184 (163,014)

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Jorgensen, FLP, family limited partnership, estate tax, discounts, section 2036

28.

Valuation Discounting and the Lottery Cases

Tax Notes, Vol. 137, No. 8, 2012
Number of pages: 3 Posted: 20 Nov 2012
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 176 (169,673)

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valuation, lottery cases, discounting, gift tax, Dickerson

29.

The Price of an FLP Annual Exclusion

Tax Notes, Vol. 128, No. 10, 2010
Number of pages: 3 Posted: 09 Sep 2010
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 170 (174,930)

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gifts, gift tax, annual exclusion, family limited partnership, FLP, Price, Hackl

30.

What's Wrong with a Federal Inheritance Tax?

Number of pages: 38 Posted: 05 Aug 2013 Last Revised: 17 Sep 2013
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 168 (176,726)

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inheritance tax, estate tax, equity, compliance, legislation

31.

Morgens: More QTIP Mischief

Tax Notes, Vol. 128, No. 3, 2010
Number of pages: 4 Posted: 24 Jul 2010
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 167 (177,620)

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qualified terminable interest property, QTIP, marital deduction, section 2035, section 2207A, Morgens, Mellinger, estate tax, gift tax

32.

Boomer-Ang Eldercare: Deductible Claim?

Tax Notes, Vol. 134, No. 5, 2012
Number of pages: 4 Posted: 06 Feb 2012
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 164 (180,382)

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estate tax, eldercare, deduction, section 2053, claim against the estate, Olivo, bequest, oral contract

33.

Toward a Reality-Based Estate Tax

Boston College Law Review, Vol. 57, No. 3, 2016, University of Baltimore School of Law Legal Studies Research Paper No. 2016-09
Number of pages: 25 Posted: 22 May 2016 Last Revised: 30 Aug 2016
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 151 (193,434)

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estate tax, valuation, FLP discounts, GRAT, CLAT, actuarial tables, QTIP, charitable deduction, marital deduction

34.

Gross: FLP Sequence and its Consequence

Tax Notes, Vol. 121, No. 9, 2008
Number of pages: 3 Posted: 02 Dec 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 149 (195,543)

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FLP, family limited partnership, gift tax, indirect gift, Gross, Holman, Jones, Shepherd, step transaction doctrine, economic risk

35.

Federal Taxes on Gratuitous Transfers: Law and Planning

J. Dodge, W. Gerzog, & B. Crawford, FEDERAL TAXES ON GRATUITOUS TRANSFERS: LAW AND PLANNING, Wolters Kluwer, 2011, FSU College of Law, Public Law Research Paper No. 588
Number of pages: 79 Posted: 06 Mar 2012 Last Revised: 06 Apr 2012
Joseph M. Dodge, Wendy C. Gerzog and Bridget J. Crawford
Florida State University - College of Law, University of Baltimore - School of Law and Pace University School of Law
Downloads 148 (196,633)

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estate, gift, tax, legal education, estate planning

36.

Mortgages and Conservation Easements: Not a Good Mix

Tax Notes, Vol. 132, No. 4, p. 437, 2011, University of Baltimore School of Law Legal Studies Research Paper
Number of pages: 6 Posted: 25 Jul 2011
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 144 (201,036)

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charitable deduction, conservation easement, facade easement, income tax, tax penalties, Kaufman

37.

Koons: Interest Deduction and FLP Valuation Practice Pointers

Tax Notes, Vol. 140, No. 4, 2013
Number of pages: 5 Posted: 22 Jul 2013
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 139 (206,848)

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FLP Valuation, Administrative Estate Tax Expense, Interest Deduction, Estate Tax, Family Limited Partnership, Koons

38.

Hester: A Saga of Greed

Tax Notes, Vol. 115, p. 669, May 14, 2007
Number of pages: 3 Posted: 17 May 2007
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 139 (206,848)

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stolen property, wrongdoer's estate, estate tax, section 2031, section 2033, section 2053, claims against the estate, QTIP

39.

Valuing Fractional Interests in Art for Estate Tax Purposes

Tax Notes, Vol. 139, No. 9, 2013
Number of pages: 4 Posted: 31 May 2013
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 137 (209,315)

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valuation, estate tax, fractional interests, fractional interests in art, LLC, section 2703, restricted agreements, discounts, Elkins

40.

FLP in the Black

Tax Notes, Vol. 127, No. 3, 2010
Number of pages: 5 Posted: 19 Apr 2010
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 134 (213,090)

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estate tax, family limited partnership, FLP, section 2036, bona fide sales, marital deduction, administrative expense, section 2056, section 2053, valuation discounts, estate of Black

41.

Shapiro: Palimony and the Estate Tax

Tax Notes, Vol. 131, No. 8, 2011
Number of pages: 3 Posted: 24 May 2011
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 129 (219,539)

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palimony, estate tax, deduction, claim against the estate, Shapiro

42.

Disclaimers and Defined Value Clauses: Christiansen

Tax Notes, Vol. 119, No. 1, 2008
Number of pages: 5 Posted: 08 Apr 2008 Last Revised: 05 May 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 128 (220,863)

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estate tax, disclaimer, defined value clause, FLP, McCord, charitable lead annuity trust, CLAT, savings clause

43.

Gerson: Plain Meaning and the Gstt

Tax Notes, Vol. 114, p. 701, February 12, 2007
Number of pages: 6 Posted: 13 Feb 2007
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 128 (220,863)

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Gerson, GST, GSTT, generation-skipping, plain meaning, transfer tax

44.

The Times They are Not A-Changin': Reforming the Charitable Split Interest Rules (Again)

Chicago-Kent Law Review, Forthcoming, University of Baltimore School of Law Legal Studies Research Paper No. 2010-03
Number of pages: 41 Posted: 09 Oct 2009
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 127 (222,138)

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charitable deduction, split interest, charitable remainder trust, charitable lead trust, 1969 Tax Reform Act, philanthropy, estate tax, gift tax, income tax

45.

Alms to the Rich: The Façade Easement Deduction

Virginia Tax Review, Forthcoming, University of Baltimore School of Law Legal Studies Research Paper No. 2014-11
Number of pages: 38 Posted: 11 Jun 2014 Last Revised: 26 Sep 2014
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 124 (226,268)

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facade easement, conservation easement, charitable deduction, split interest, real property regulation, Pension Protection Act of 2006

46.

Mccord: Value of Gifts Must Be 'Tax Affected'

Tax Notes, Vol. 113, p. 913, 2006
Number of pages: 6 Posted: 06 Dec 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 119 (233,318)
Citation 1

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McCord, gift tax, estate tax, tax affecting, section 2035, net gift

47.

Another Turn with Turner

Tax Notes, Vol. 136, No. 13, 2012
Number of pages: 3 Posted: 26 Sep 2012
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 117 (236,259)

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estate tax, defined value clause, marital deduction, family limited partnership, FLP

48.

Big Bird Lays an Egg?

Tax Notes, Vol. 115, p. 385, April 23, 2007
Number of pages: 4 Posted: 24 Apr 2007
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 114 (240,730)

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section 2053, claim against the estate, postdeath events, estate tax, puppeteer, Jim Henson, separation agreement

49.

Anthony: Absolute Actuarial Tables

Tax Notes, Vol. 121, No. 4, 2008
Number of pages: 4 Posted: 29 Oct 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 112 (243,748)

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Estate Tax, Actuarial Tables, section 7520, Anthony, Shackleford, Gribauskas, Cook, section 2039

50.

The New Regs on Alternative Date Valuation

Tax Notes, Vol. 120, No. 797, 2008
Number of pages: 4 Posted: 27 Aug 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 112 (243,748)

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estate tax, alternate valuation date, section 2032, regulations, Kohler

51.

Janis: Two Perspectives of Basis

Tax Notes, Vol. 114, p. 1265, March 26, 2007
Number of pages: 4 Posted: 02 Apr 2007
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 112 (243,748)

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estate tax, section 1014, basis, Janis, duty of consistency

52.

Return to Senda: Order Determinative for Flp Discounts

Tax Notes, Vol. 110, p. 791, 2006
Number of pages: 2 Posted: 25 Aug 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 112 (243,748)

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gift tax, valuation, FLP, family limited partnership

53.

Bongard's Nontax Motive Test: Not Open and Schutt

Tax Notes, Vol. 107, pp. 1711-1716, 2005
Number of pages: 6 Posted: 24 Mar 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 112 (243,748)

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FLP, Bongard, Schutt

54.

Bigelow: The Ninth Circuit on FLPs

Tax Notes, Vol. 117, No. 12, 2007
Number of pages: 8 Posted: 17 Dec 2007
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 107 (251,792)

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FLP, estate planning, estate tax, section 2036, Bigelow, valuation, discount, bona fide sales

55.

A Simpler Verifiable Gift Tax

University of Baltimore School of Law Legal Studies Research Paper No. 2015-35
Number of pages: 34 Posted: 21 Oct 2014 Last Revised: 15 Oct 2015
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 103 (258,535)
Citation 3

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gift tax, annual exclusion, consumption exclusion, portability, compliance, valuation distortions, FLP, GRAT

56.

Kelley: A Green Light for Flps

Tax Notes, Vol. 109, p. 1467, 2005
Number of pages: 4 Posted: 25 Aug 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 103 (258,535)

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FLP, estate tax, lack of marketability discount, minority discount

57.

Caering About the Credit for Prior Transfers

Tax Notes, Vol. 129, No. 9, 2010
Number of pages: 4 Posted: 03 Dec 2010
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 101 (262,005)

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le Caer, credit , tax on prior transfers, TPT, section 2013, estate tax, recent cases

58.

Façade Easement: Inexpert Valuation

Tax Notes, Vol. 136, No. 2, 2012
Number of pages: 5 Posted: 09 Jul 2012
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 97 (269,052)

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Dunlap, expert valuation, facade easement, charitable deduction, burden of proof

59.

Davenport: Res Judicata Applied

Tax Notes, Vol. 115, No. 12, 2007
Number of pages: 6 Posted: 25 Jun 2007
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 97 (269,052)

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gift tax, estate tax, res judicata, collateral estoppel, transferee liability, valuation

60.

Conservation Easements Under Turner and Glass

Tax Notes, Vol. 112, p. 179, July 10, 2006
Number of pages: 5 Posted: 17 Jul 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 94 (274,617)

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conservation easement, charitable deduction, estate tax, gift tax, income tax, estate planning, Turner, Glass

61.

Graev: Conditional Facade Easement

Tax Notes, Vol. 140, No. 14, 2013
Number of pages: 4 Posted: 01 Oct 2013
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 93 (276,568)

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facade easement, charitable deduction, Graev, conditional gift, National Architectural Trust, Procter

62.

Davis and Whiting: Qtip Income Interests and Intent

106 Tax Notes 1597
Number of pages: 3 Posted: 06 Feb 2007
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 91 (280,336)

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marital deduction, QTIP, Davis, Whiting

63.

When Sommers are Winters: Do Blanks Denote Revocability?

Tax Notes, Vol. 138, No. 12, 2013
Number of pages: 4 Posted: 25 Mar 2013
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 89 (284,321)

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equitable apportionment, LLC, gift completion, defined value clause, issue preclusion, collateral estoppel, gift tax, estate tax, annual exclusion

64.

The Marital Deduction QTIP Provisions: Illogical and Degrading to Women

UCLA Women's Law Journal, Vol. 5, No. 2, 1995
Number of pages: 28 Posted: 08 Oct 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 89 (284,321)

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QTIP, marital deduction, demeans women, qualfied terminable interest property, section 2056

65.

Negron: Circuits Now Split 2-2

Tax Notes, Vol. 123, No. 6, 2009
Number of pages: 4 Posted: 21 May 2009
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 88 (286,360)

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estate tax, Negron, lottery payments, non-marketability discount, valuation, Ithaca Trust

66.

Buder: The Extent of Equitable Recoupment

Tax Notes, Vol. 110, pp. 1361-1364, March 20, 2006
Number of pages: 4 Posted: 29 Mar 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 88 (286,360)

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equitable recoupment, QTIP, marital deduction

67.

The Collision between Crts and the Upc Elective Share

Tax Notes, Vol. 111, May 2006
Number of pages: 7 Posted: 08 Jun 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 87 (288,446)

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Rev. Proc. 2005-24, Notice 2006-15, CRAT, CRUT, CRT, UPC Elective Share, Spousal Share, charitable deduction

68.

Van Alen: A Reasonable Consistency

Tax Notes, Vol. 142, No. 2, 2014
Number of pages: 4 Posted: 13 Jan 2014
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 83 (296,945)

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estate tax, duty of consistency, special use valuation, basis, Van Alen, section 2032A

69.

The Final Grat Regulations: Schott Shot Down

Tax Notes, Vol. 107, p. 1175, 2005
Number of pages: 6 Posted: 24 Mar 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 81 (301,366)

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GRATs, 2702, Gift Tax Regs., valuation, Schott

70.

Annuity Tables Versus Factually-Based Estate Tax Valuation: Ithaca Trust Revisited

Real Property, Probate and Trust Law Journal, Vol. 38, No. 4, Winter 2004
Number of pages: 36 Posted: 18 Apr 2004
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 75 (315,282)

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71.

Contingencies and the Estate Tax

Florida Tax Review, Vol. 5, No. 2, 2001
Number of pages: 60 Posted: 08 Oct 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 72 (322,561)

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72.

Donovan and Davis: Two More Lottery Cases

Tax Notes, Vol. 110, p. 543, 2006
Number of pages: 5 Posted: 24 Mar 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 71 (325,092)

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Donovan, Davis, Lottery, Estate Tax, Valuation, Annuities

73.

An Attempt to Legislate?

Tax Notes, Vol. 117, No. 1, 2007
Number of pages: 5 Posted: 03 Oct 2007 Last Revised: 24 Sep 2009
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 69 (330,233)

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estate tax, Roski, closely held business, farm, section 6166, lien, tax gap

74.

Duty of Consistency and Marital Deduction: Horse and Carriage

Tax Notes, Vol. 108. pp. 1463- 1472, September 19, 2005
Number of pages: 10 Posted: 28 Mar 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 66 (338,201)

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marital deduction, duty of consistency, 2056

75.

The Marriage Penalty: The Working Couple's Dilemma

Fordham Law Review Vol. 47, No. 1978
Number of pages: 23 Posted: 02 Dec 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 58 (360,826)

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marriage penalty, income tax, two-earner couple

76.

How Do D'Ambrosio and Wheeler Fit into the Flp Debate?

Tax Notes, Vol. 107, pp. 387-392, April 2005
Number of pages: 6 Posted: 24 Mar 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 53 (376,555)

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FLPs, 2036, Kimbell, Wheeler, Turner, D'Ambrosio

77.

On Public Policy Grounds, a Limited Tax Credit for Child Support and Alimony

The American Journal of Tax Policy, Vol. 11, p. 321, 1994
Number of pages: 20 Posted: 02 Dec 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 52 (379,792)

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Child Support, Alimony, Tax Policy, Tax Credit, Income Tax, Divorce, Family Law

78.

Focardi: Cook-Ed, Not Schott

Tax Notes, Vol. 111, May 2006
Number of pages: 4 Posted: 08 Jun 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 50 (386,373)

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GRAT, 2702, valuation, gift tax, Focardi, Cook, Schott

79.

Amlie Feud

Tax Notes, Vol. 112, p. 877, September 4, 2006
Number of pages: 5 Posted: 11 Sep 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 47 (396,638)

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Valuation, 2703, Estate Tax, Amlie, Blount, Family Discord

80.

The Illogical and Sexist QTIP Provisions: I Just Can't Say it Ain't so

North Carolina Law Review, Vol. 76, No. 5, 1998
Number of pages: 12 Posted: 14 Oct 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 44 (407,306)

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QTIP, qualified terminable interest property, marital deduction, sexist, degrading women, estate tax, gift tax, transfer tax

81.

Solutions to the Sexist QTIP Provisions

Real Property Probate and Trust Journal, Vol. 35, p. 97, 2000
Number of pages: 33 Posted: 11 Oct 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 42 (414,699)

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QTIP, qualified terminable interest property, marital deduction, sexist

82.

Saigh it Isn't so!

Tax Notes, Vol. 107, p. 115, 2005
Number of pages: 4 Posted: 24 Mar 2006
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 39 (426,293)

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Saigh, transferee liability, estate tax, Baptiste, Poinier

83.

Estate of Clack: Adding Insult to Injury, or More Problems with the QTIP Tax Provisions

Southern California Review of Law and Women's Studies, Vol. 6, No. 1, 1996
Number of pages: 35 Posted: 11 Oct 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 38 (430,425)

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Estate of Clack, QTIP, qualified terminable interest property, marital deduction, demeans women

84.
Downloads 31 (460,367)

Contingencies and the Gift Tax

Tax Notes, Vol. 93, No. 7, 2001
Number of pages: 9 Posted: 11 May 2012
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 31 (472,215)

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2001 Tax Act, gift tax, estate tax repeal, contingencies

Contingencies and the Gift Tax

Tax Notes, Vol. 93, No. 7, November 12, 2001
Posted: 07 Nov 2001
Wendy C. Gerzog
University of Baltimore - School of Law

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85.

The Lottery Cases and Ithaca Trust

Tax Notes, Vol. 101, No. 2, 2003
Number of pages: 3 Posted: 12 May 2012
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 30 (465,108)

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lottery, valuation, estate tax, postdeath facts, actuarial tables, Ithaca Trust, Shackleford, Gribauskas

86.

A Hypothetical: Quinlan Under Ohio Law

Akron Law Review, Vol. 10, No. 1, 1976
Number of pages: 26 Posted: 04 Dec 2008
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 20 (519,341)

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Quinlan, legal definition of death, physician's duty of care, extraordinary medical care, physician's liability, incompetency, right to privacy, consent

A Different Take on the FLP Valuation Game

Tax Notes, Vol. 97, No. 5, November 4, 2002
Number of pages: 4 Posted: 10 May 2012
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 19 (543,765)

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family limited partnership, FLP, section 2036, estate tax, valuation discounts, Strangi, Byrum, Eisenberg, Smith

A Different Take on the Flp Valuation Game

Tax Notes, Vol. 97, No. 5, November 4, 2002
Posted: 31 Oct 2002
Wendy C. Gerzog
University of Baltimore - School of Law

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88.

Ithaca Trust and Section 2053: Smith, McMorris, and O’Neal

Tax Notes, Vol. 95 , No. 3, 2002
Number of pages: 3 Posted: 11 May 2012
Wendy C. Gerzog
University of Baltimore - School of Law
Downloads 18 (531,022)

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Ithaca Trust, estate tax, deductions, postdeath facts, section 2053, Smith, McMorris, and O'Neal

89.

Portability, Marital Wealth Transfers, and the Taxable Unit

Controversies in Tax Law: A Matter of Perspective (Anthony C. Infanti ed.) (Ashgate), April 2015
Number of pages: 21 Posted: 07 Jul 2014 Last Revised: 14 Jun 2019
Bridget J. Crawford and Wendy C. Gerzog
Pace University School of Law and University of Baltimore - School of Law
Downloads 15 (548,527)

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estate tax, portability, applicable exemption, unified credit, QTIP, trusts, trust, gender, women, tax

90.

Estate of Noble: Postdeath Sale is Best Indicia of Stock's Value

Tax Notes, Vol. 106, No. 6, February 7, 2005
Posted: 04 Feb 2005
Wendy C. Gerzog
University of Baltimore - School of Law

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91.

Okerlund and Polack: How Probative are Postgift Facts?

Tax Notes, Vol. 105, No. 2, p. 196, October 11, 2004
Posted: 08 Oct 2004
Wendy C. Gerzog
University of Baltimore - School of Law

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92.

Ithaca Trust and Section 2053: Smith, Mcmorris, and O'Neal

Tax Notes, Vol. 95, No. 3, April 22, 2002
Posted: 19 Apr 2002
Wendy C. Gerzog
University of Baltimore - School of Law

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