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Jun 1, 2005 12:00 PM, Rorie M. Sherman Editor in Chief
By: Rorie M. Sherman Editor in ChiefFrom David T. Leibell and Daniel L. Daniels of Cummings & Lockwood, LLC, Stamford, Conn., we have this update:
IRS approves disclaimer of residuary estate to private foundation. In Private Letter Ruling 200519042 (released May 13), the Service ruled that a daughter's disclaimer of an undivided portion of her interest in a parent's residuary estate is a qualified disclaimer, and the disclaimed interest passing to a private foundation will qualify for the estate tax charitable deduction. The ruling provides a good road map to qualifying a disclaimer when the disclaimant has a continuing role in the foundation.
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