Van Alen: A Reasonable Consistency

Abstract

In Van Alen, the Tax Court held that the duty of consistency required that two of the decedent’s children use the section 2032A basis valuation figures to determine gain on the sale of their interest in the decedent’s ranch, which was left to them in trust. The siblings had argued that their stepmother erroneously completed their father’s estate tax return.

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

JEL Classification: H20, H24, H25, H29, K34