Who pays the estate tax?

Sep 12, 2008 3 Replies

If the assets in an estate go away [e.g., invested in stocks and the value plunges or a house burns down or something] so that there's not enough capital left in the estate to pay the estate taxes, who's on the hook for the difference? The heirs haven't gotten anything from the estate [indeed, some of the heirs might not even KNOW they've received a bequest], hardly seems fair for them to have to pay [but then when has 'fair' ever affected IRS rules..:o)] Could the executor be stuck with the tax bill? (on the theory that the executor was responsible for the management of the estate until it is closed)? Can an estate declare bankruptcy? :o).



I know about the dual-valuation [on the date of death and six months after], but what got me thinking about this was the HUGE plunge of United stock the other day (or Enron or any stock that vanishes pretty much overnight): if a lot of the estate's assets were in United stock and the estate were evaluated *before* the plunge, there might well not be enough assets left to pay the estate tax. And so who ends up paying it?



I'm starting to think that for volatile assets, what the executor might have to do to be prudent is liquidate some of the assets [sufficient to cover the [estimated] estate tax] into something more solid.



/Bernie\


I think that in a case like this, the IRS would be like any other creditor of the estate. If the failure to pay was due to the executor's negligence (e.g. risky investments, failure to have fire insurance, etc.) then the executor could be on the hook. But otherwise, no one is responsible - rather no living person is responsible.

Stu

If the estate is insolvent the IRS must get paid first to the extent possible (31 USC 3713) or the executor can be held personally liable.

I don't know what personal libility problems the executor might face under state law for not better performing his fiduciary responsibilities. When I was executor of an Illinois estate that involved only cash bequests the attorney advised me to convert all investments to cash as soon as I got the necessary appointment papers from the Probate Court.

Thanks for the info. I guess the simple answer to my question is "the executor". The executor has a fiduciary responsibility for the assets in the estate and the IRS [and the heirs, too, I bet] would go after the executor if the assets disappeared, and the executor would then have the burden of proving that they acted reasonably and prudently. Sure sounds like "convert everything to cash as fast as you can" is the best plan..:o)

/Bernie\

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