U.S. Tax Court Rules on a Case of Intergenerational Split Dollar: Estate of Levine

On February 28, 2022, the United States Tax Court ruled in favor of the taxpayer in Estate of Levine v. Commissioner concerning the estate tax consequences of a split-dollar life insurance arrangement. This same court ruled against the taxpayer in the 2021 case Estate of Morrissette v. Commissioner. The two cases illustrate that when it comes to this complicated estate planning strategy, facts can make all the difference.