id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-416	Fogel, Bradley E.S.	Back to the Future Interest: The Origin and Questionable Legal Basis of the Use of Crummey Withdrawal Powers to Obtain the Federal Gift Tax Annual Exclusion	2022	58	.pdf	application/pdf	28428	1821	68	Further, this difference is dispositive in other transfer tax contexts.240 The courts’ erroneous decisions allowing Crummey powers may be partially attributed to the IRS’s failure to litigate the fundamental validity of Crummey withdrawal powers. Although the Tax Court has subsequently decided a few cases that involve Crummey powers, none of these cases involve the fundamental efficacy of Crummey withdrawal powers.	cache/ftr-416.pdf	txt/ftr-416.txt