[Anthony] Marshall criticized JPMorgan for challenging the 2003 transfer to him of Mrs. Astor’s seaside home in Maine, and $5 million from her. Mr. Marshall’s court papers pointed out that the bank had recently notified his lawyers that they had filed amended tax forms for Mrs. Astor, naming the items taxable income rather than gifts. Consequently, Mr. Marshall could face millions of dollars more in income tax.No wonder Mr. Marshall isn't keen to see JPMorgan/Chase appointed as an administrator of his mother's estate!
Thursday, August 23, 2007
Astor Estate: JPMorgan Plays the Tax Card
From yesterday's item in The New York Times:
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Those must have been some extraordinary services rendered by Marshall in 2003 to merit so generous a payment! I wonder what they were? Yet despite such meritorious performance, he had to be relieved of his duties just 3 years later?
I suspect that no gift tax return was filed on the 2003 transfer, and so the estate is trying to avoid tax penalties. The income tax would likely be less than the proper amount of gift tax due, but any such savings might not benefit Marshall under the 1997 will.
Still, avoiding the gift tax will have the effect of enlarging the estate and the federal estate tax due, so this seems odd to me.
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