Recent developments in transfer taxes should be on every estate planner’s radar. In 2018, the following three cases made waves.

First, in United States v. Paulson, 331 F. Supp. 3d 1066 (S.D. Cal. 2018), the U.S. District Court of the Southern District of California held the former trustee of a decedent’s revocable living trust, who had been succeeded as trustee nine years after the decedent’s death, personally liable under Section 6324(a)(2) of the Internal Revenue Code of 1986, as amended (the code), for the full estate tax obligation of the decedent’s estate, including estate taxes which had accumulated beyond the period for which he served as trustee.