Brandon Ridge Partners v. United States, 2007 TNT 148-14 (M.D. Fl. 2007); Estate of Hicks v. Commissioner, T.C. Memo. 2007-182 - One case is worth analyzing the other case is worth reversing.

In Brandon Ridge, the United States District Court in the Middle District of Florida jumped in the foray of TEFRA and the statue of limitation. The lesson from the case is clear- just because the Court cites to a case doesn’t mean the court has necessarily read the case. I would be shocked if Brandon Ridge is not appealed and reversed faster than one can say 11th Circuit.

In Hicks, Judge Holmes wrote an opinion that was not only a legal opinion but an educational treatise to Trust and Estate attorneys and all planners on how to protect one’s client by using the probate court without run afoul of Estate of Bosch.
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