When one of the founding partners of a regional law firm has the firm’s estate group handle his planning, they are likely to do a pretty good job. That may well be the moral in the Tax Court decision in the case of the Estate of Barbara M. Purdue. I look at the case as another illustration of Reilly’s Fourth Law of Tax Planning - Execution isn’t everything, but it’s a lot.
The IRS was looking for over $4 million in estate and gift tax from Mrs. Purdue’s estate. She died at the age of 95 in 2007 and had some colorful items in her biography. During WWII she was a Red Cross hospital aide on the USS Comfort, the only hospital ship ever struck by a Kamikaze. Her husband Robert, one of the founders of Seattle law firm Montgomery Purdue Blankinship & Austin PLLC died in 2001. They had five children and in the words of the decision “multiple grandchildren and great-grandchildren”. As of 1999, their net worth was approximately $28 million mostly marketable securities and also an interest in a commercial building in Hawaii (the Hocking Building).