Estate Tax Advisory Opinions

Estate Tax Advisory Opinions (TSB-A)

An Advisory Opinion is issued at the request of a person or entity. It is limited to the facts set forth therein and is binding on the Department only with respect to the person or entity to whom it is issued and only if the person or entity fully and accurately describes all relevant facts. An Advisory Opinion is based on the law, regulations, and Department policies in effect as of the date the Opinion is issued or for the specific time period at issue in the Opinion.

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Number

Petitioner

2008

As announced in August 2008, the Department has transferred responsibility for Advisory Opinions from the Taxpayer Guidance Division to the Department's Office of Counsel. Among other changes, the format of the Advisory Opinions issued by the Office of Counsel will appear slightly different than the format used by the Taxpayer Guidance Division. During the transition period, which began in 2008 and is scheduled to be completed in 2009, the Department will issue Advisory Opinions in two formats. Those opinions issued by the Taxpayer Guidance Division will continue in the previous format, while opinions written by Office of Counsel will be issued in the revised format. One of the most noticeable changes in format is that the opinions issued by the Office of Counsel, for petitions received on or after August 8, 2008, will not contain the petitioner’s name, address, or identification numbers when posted on the Department's Web site. Both formats are official Advisory Opinions, and all are binding on the Department with respect to the person or entity to whom they are issued and the facts stated in the Opinion. For more information on the transition and the procedures, see TSB-M-08(10)C, (5)I, (5)M, (3)R, (8)S, Changes in Procedures for Obtaining Guidance from the Tax Department.

TSB-A-08(1)M

Nilda S. Martinez-Catinchi

2007

TSB-A-07(1)M

Deborah Rothman as Trustee of the X Trust Agreement

2006

TSB-A-06(6)I, (4)M

Richard I. Furman (on behalf of his wife, Rosemary F. Furman)

2001

TSB-A-01(1)M

Lawrence A. DeAngelus

2000

TSB-A-00(2)M

John T. Sharkey

TSB-A-00(1)M

Northern Trust Bank of Florida, NA

1998

TSB-A-98(19)C, (12)I, (3)M

Comptroller of the State of New York

1993

TSB-A-93(3)M

Jamaica Savings Bank FSB

TSB-A-93(2)M

Metropolitan Moving and Storage Association, Inc.

1992

TSB-A-92(3)M

Marine Midland Bank, N.A.

TSB-A-92(2)M

Donald C. Lubick

1985

TSB-A-85(3)

R. Walter Kaszubinski

TSB-A-85(2)

Barbara O. Marvin

TSB-A-85(1)

Mr. Robert F. Hall

1983

TSB-A-83(2)M

Philip A. Rubenstein

Related Links...
•	Estate Tax Resources and Publications
•	Select a Different Advisory Opinion Tax Type
•	Publications and Bulletins Home Page
•	Forms and Instructions Home Page

Last Modified: January 6, 2009