Estate of Anne Milner Fields, Deceased, Bryan K. Milner Executor Petitioner— v. Commissioner of Internal Revenue Respondent—
June 8, 2026·25-60403·Panel Decision·Stuart Kyle Duncan·By Maria Santos
The United States Court of Appeals for the Fifth Circuit affirmed the Tax Court's decision regarding the estate tax treatment of Anne Milner Fields's estate. The court found that the estate's asset transfers did not qualify for the bona fide sale exception under the Internal Revenue Code.
This case involves the estate of Anne Milner Fields and the tax implications of asset transfers made prior to her death. The Internal Revenue Service audited the estate and assessed a penalty for underreporting the estate’s value.
The court’s reasoning
The court concluded that the estate did not show that the asset transfers served a substantial non-tax purpose, thus failing to meet the bona fide sale exception under I.R.C. § 2036(a). The court also found that the estate acted negligently in its tax reporting.
The Estate has not shown that Fields’s assets were transferred for a non-tax purpose, so the bona fide sale exception in I.R.C. § 2036(a) does not apply.
Estate of Fields v. Comm’r, T.C.M. (RIA) 2024-090 at 13 (2024)
What it means going forward
The ruling reinforces the IRS’s authority to scrutinize estate valuations and impose penalties for underreporting, emphasizing the importance of demonstrating non-tax motivations for asset transfers.
