IRS Says Deceased Oil Tycoon’s Nephew Moved Funds to Avoid Taxes

An oil entrepreneur’s estate must include for tax purposes $17 million in transferred assets that her great-nephew restructured, the IRS told the Fifth Circuit, urging the appeals court to uphold the disallowance of a $6.2 million deduction.

The US Tax Court properly held that Bryan Milner’s transfer of most of Anne Milner Fields’ $17 million in personal assets to an entity he’d recently formed wasn’t a bona fide sale under IRC Section 2036(a) because it didn’t serve a substantial purpose beyond tax avoidance, the agency said Monday in a brief filed with the US Court of Appeals for the Fifth Circuit.

Under the transaction, Fields became a limited partner in AM Fields LP and received an interest of more than 99.99%, while Milner’s other business—AM Fields Management LLC—was general partner and received an interest below 0.01%.

“Undergirding the Tax Court’s skepticism is the speed at which Mr. Milner formed AM Fields and transferred Ms. Fields’s assets into it, as her health declined at the same time: a fall, a heart attack, and a suggestion of hospice by two physicians within a few weeks,” the IRS’ brief said.

Milner appealed an earlier Tax Court decision that disallowed his claimed $6.2 million discount on the estate’s federal tax bill, arguing that the court made “speculative assumptions of motive” and ignored valid non-tax purposes for the transfers. Instead, he argued that he made the transfers to protect his aunt in the midst of her battle with Alzheimer’s disease.

“Mr. Milner’s actions and other evidence contradict his testimony and, for some of the purported goals, there is no corroborating evidence at all,” the IRS said in response.

The agency added that the Tax Court also properly assessed an accuracy-related penalty under Section 6662(a) because the estate didn’t satisfy its burden of showing reasonable reliance on professional advice.

Gray Reed & McGraw represents the estate.

The case is Estate of Fields v. Commissioner, 5th Cir., No. 25-60403, appellee’s brief filed 2/23/26.