By Von Sanborn, Matthew Lee and Casey O’Connor (August 29, 2018, 3:04 PM EDT) -- A recently issued private letter ruling by the Internal Revenue Service illustrates the importance of careful estate planning and exposes an imbalance between the treatment of certain gifts for U.S. income tax and gift tax purposes. In PLR 201825003, the IRS held that a donor's gift of art to two museums would be a completed gift for U.S. gift tax purposes even though she reserved the option to terminate the gift upon the occurrence of certain conditions. While acknowledging the donor's reserved rights, the IRS concluded that the donor did not retain sufficient dominion and control over the artwork to cause the gifts to be incomplete....