9th Circuit Affirms Decision Including Entire Value of GRAT in Decedent’s Gross Estate

On April 28, 2020, the U.S. Court of Appeals for the Ninth Circuit issued its opinion in Badgley v. U.S.  In so doing, the Court affirmed a lower court determination that the entire date-of-death value of the assets of a Grantor Retained Annuity Trust (“GRAT”) were includible in the settlor’s gross estate for federal estate tax …