Estate of Morrissette v. Commissioner, 146 T.C. No. 11 (April 13, 2016) The Tax Court’s ruling in Morrissette is very important to the estate planning community, in that, intergenerational split-dollar life insurance arrangements have become much more popular since the IRS released its final split-dollar regulations in 2003. Yet, widespread use of this technique has been suppressed by uncertainty with respect to the tax result. Further, the IRS has oftentimes taken the position (in audits) that a lump sum premium payment should be treated as a gift to the lower generation even if the economic benefit regime was used to…