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?