If you're in that position that you know you're going to spend the money anyway, you're far better off to pay it now and relieve yourself of the risk of dying in that interim period and paying a significant tax rate on that.

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To the extent that it pushes all your other assets over those thresholds, now you're paying a 50 percent tax.

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Private Letter Ruling is where somebody requests a ruling from the IRS on a particular set of facts as they apply to them. The IRS rules with respect to that particular situation, but that does not have binding effect on everybody's situation.

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