Associate Theresa Balducci
co-authored "Sumner Redstone’s 40-Year-Old-Gift," 140 Tax Notes
833 (2013), with Bridget J. Crawford. In this article the authors discuss the alleged gift tax deficiency case against media mogul Sumner Redstone. The IRS argues that Mr. Redstone made a taxable gift in 1972 when, in connection with the settlement of an intrafamily dispute, he transferred shares of a family-owned business to trusts for his children. The authors suggest that the integrity of a self-reporting gift tax system depends in part on the ability of the IRS to seek to impose tax on non-disclosed transfers, however old they may be. Sumner Redstone likely will face a tax bill well in excess of a million dollars.