Whether the Tax Court 1) should have valued the charitable gift at Victoria’s Date of Death, 2) even if post-death events could be considered, the Tax Court erred by not accounting for a decline in value of Victoria’s shares caused by economic forces, and 3) the Tax Court erred by upholding the accuracy-related penalty under I.R.C. § 662.
Ramos, Christian, "Dieringer v.Comm'r of Internal Revenue" (2020). GGU Tax & Estate Planning Review. 4.