{"podcast":{"title":"Swear on the Stand","slug":"swear-on-the-stand-7111404","podcast_index_feed_id":7111404,"rss_url":"https://anchor.fm/s/fddb5314/podcast/rss","website_url":"https://podcasters.spotify.com/pod/show/danielswear","image_url":"https://d3t3ozftmdmh3i.cloudfront.net/staging/podcast_uploaded_nologo/42490093/42490093-1732466737482-64af1021e8b8d.jpg","author":"Daniel W. Swear","episode_count":193,"summary":"Court decisions are complex and difficult to digest. This podcast is designed to educating listeners on current legal decisions in a fun and interesting way. Researched by me and produced with the assistance of AI.","last_synced_at":"2026-07-10T22:18:10.447360+00:00","page_url":"https://stenobird.com/podcast/swear-on-the-stand-7111404"},"episode":{"title":"Estate of Fields v. Commissioner: Estate Tax Valuation Appeal","slug":"estate-of-fields-v-commissioner-estate-tax-valuation-appeal","published_at":"2026-06-16T12:00:00+00:00","page_url":"https://stenobird.com/podcast/swear-on-the-stand-7111404/estate-of-fields-v-commissioner-estate-tax-valuation-appeal","show_page_url":"https://stenobird.com/podcast/swear-on-the-stand-7111404","url":"https://podcasters.spotify.com/pod/show/danielswear/episodes/Estate-of-Fields-v--Commissioner-Estate-Tax-Valuation-Appeal-e3khbem","audio_url":"https://anchor.fm/s/fddb5314/podcast/play/121203606/https%3A%2F%2Fd3ctxlq1ktw2nl.cloudfront.net%2Fstaging%2F2026-5-9%2Fa10881f5-739a-73a6-ceca-1501bb1c0c43.m4a","summary":"This episode is an opinion from the Fifth Circuit Court of Appeals regarding a dispute between the Estate of Anne Milner Fields and the Internal Revenue Service . The court examined whether $17 million in assets transferred into a limited partnership just before the decedent's death should be taxed at their full value or at a discounted partnership rate. Ultimately, the court affirmed the Tax Court's ruling , finding that the transfers lacked a substantial non-tax purpose and were primarily motivated by estate tax avoidance . Because the executor could not prove the arrangement was a bona fide sale , the assets were recaptured into the gross estate at their original market value . Furthermore, the court upheld a 20% negligence penalty , concluding that the significant tax undervaluation was "too good to be true" for a sophisticated executor to accept in good faith.","meta_description":"This episode is an opinion from the Fifth Circuit Court of Appeals regarding a dispute between the Estate of Anne Milner Fields and the Internal Revenue S…","key_points":[],"chapters":[],"topics":[],"duration_seconds":3305,"processing_state":"not_requested","actions":[{"name":"request_transcript","method":"POST","url":"https://stenobird.com/v1/public/podcasts/swear-on-the-stand-7111404/episodes/estate-of-fields-v-commissioner-estate-tax-valuation-appeal/transcription-requests","description":"Idempotently request low-priority transcript generation for this episode."},{"name":"read_markdown","method":"GET","url":"https://stenobird.com/podcast/swear-on-the-stand-7111404/estate-of-fields-v-commissioner-estate-tax-valuation-appeal.md","description":"Read the agent-friendly Markdown representation of this episode resource."}]}}