Weatherby & Associates, PC

Part-sale/part-gift
A transfer of property for less than its fair market value, creating a transaction that is in part a sale (receipt by the transferor of some conideration or the property) and in part a gift (receipt by the transferee of some of the porperty for no adequate consideration).

Per se rule on incidents of ownership
A position of the IRS, now apparently relaxed, that incidents of ownership on a life insuracne policy held by the insured in a fiduciary capacity would cause the insured's estate to include the proceeeds, notwithstanding, that the insured could receive no personal benefit from the trust or estate.

Personal holding company
A closely held corporation that primarily serves to own the stock of other corporations.

Personal holding company tax
A surtax imposed on closely held corporations that receive most of their income from passive sources, such as rents, royalities, interest, and dividends.

Pick-up tax
A state death tax measured by the alllowable federal estate tax credit for state death taxes.

Pooled income fund
A charitable trust created and maintained by a charitable institution to which individual donors may make gifts and as to which the donor or some designated person retains for life (or a term of years) the right to a proportionate share of the trust's income, the remainder being vested in the charity.

Power of appointment
A right held by one person to designate who shall possess or enjoy property that that person does not own. Estate and gift taxation are governed by 2041 and 2514.

Power of appointment, general
Under tax law, any power of appointment that can be exercised in favor of the holder, the holder's estate, the holder's creditors, or the creditors of he holder's estate.

Power of appointment, limited
Under tax law, any power of appointment that is not a general power of appointment. Also known as a "special" power of appointment.

Power of attorney
A document authorizing one person to represent another in specified transactions.

Private annuity
The sale, usually by one family member to another, of property or the payment of money in exchange for an agreement to make a stated periodic payment, e.g., weekly, monthly , annually, for the rest of the seller's life.

Put
The contractual right to insist that someone else purchase stock or other assets at a specified price
.