§645. Certain revocable trusts treated as part of estate — Inbound Citations
26 U.S.C. § 645
Cited by 2 provisions in release 119-102.
Citations to §645(b)(1)
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(2) Paragraph (1) shall apply with respect to an issue only if—(A) the taxpayer has complied with the requirements under this title to substantiate any item;(B) the taxpayer has maintained all records required under this title and has cooperated with reasonable requests by the Secretary for witnesses, information, documents, meetings, and interviews; and(C) in the case of a partnership, corporation, or trust, the taxpayer is described in section 7430(c)(4)(A)(ii).Subparagraph (C) shall not apply to any qualified revocable trust (as defined in section 645(b)(1)) with respect to liability for tax for any taxable year ending after the date of the decedent’s death and before the applicable date (as defined in section 645(b)(2)).
Citations to §645(b)(2)
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(2) Paragraph (1) shall apply with respect to an issue only if—(A) the taxpayer has complied with the requirements under this title to substantiate any item;(B) the taxpayer has maintained all records required under this title and has cooperated with reasonable requests by the Secretary for witnesses, information, documents, meetings, and interviews; and(C) in the case of a partnership, corporation, or trust, the taxpayer is described in section 7430(c)(4)(A)(ii).Subparagraph (C) shall not apply to any qualified revocable trust (as defined in section 645(b)(1)) with respect to liability for tax for any taxable year ending after the date of the decedent’s death and before the applicable date (as defined in section 645(b)(2)).