There are lots of unanswered tax questions, according to the Tax Notes writeup on reactions to Rev. Proc. 2009-20 and Rev. Rul. 2009-09,the Madoff/ponzi scheme relief rulings announced yesterday. Here's one I should have thought of earlier:
Taxpayer made a gift to child of a $2 million interest in the Madoff fund. Taxapayer used up his unified credit to avoid gift tax, but did file a gift tax return. Does he get his unified credit back now? Does it depend upon how long ago he made the gift?
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Is there an estate tax counterpart to this interesting question? What if an estate a couple of years ago paid a $200,000 estate tax only because a Madoff "account" caused the estate to be valued at more than the exempt amount? If the actual value of the Madoff account was zero, should the IRS refund the tax?
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