The Ninth Circuit Court of Appeals has held that a donor who gave shares in a business to both a trust for a child and a charity, with the requirement that the trust transfer additional shares to the charity if the finally determined value of the shares it received would exceed the value the donor could transfer to the child without exceeding her lifetime gift exclusion, is entitled to a charitable contribution deduction for the value of additional shares transferred to the charity by the trust. The estate plan of Anne Petter, an heir to the United Parcel fortune, was complicated. She gave shares in a family LLC to trusts for her children, but wanted the gift to them not to exceed the...