# Defined Value Clauses and the Wandry Clause: Formula Gifts That Survive an Audit

> How a Wandry or defined value clause caps a gift of LLC units at a dollar amount, the cases that upheld and rejected them, and the California rules that apply.

Source: https://ridleylawoffices.com/defined-value-clause-wandry/

By Eric Ridley, attorney, Ridley Law. Updated October 2026.

**Estate size this page matters for:** $15 million to $100 million, and $100 million and up. Anyone making a large gift of an LLC, partnership or company interest that has no market price needs this, including families below the $15 million single or $30 million married line who are using their exemption now. For the wider strategy picture, see [ultra-high-net-worth estate planning in California](https://ridleylawoffices.com/ultra-high-net-worth-estate-planning-california/).

**Short answer –**A Wandry clause, also called a defined value clause, gives away a dollar amount of an entity instead of a fixed number of units. If the IRS later proves the units were worth more, fewer units count as the gift and the rest stay with the donor, so the gift doesn’t grow past the exemption you meant to use. The Tax Court approved this design in *Wandry v. Commissioner* (2012), and the IRS announced it generally won’t follow that decision. A version that sends any excess to charity has firmer footing: the Ninth Circuit, whose decisions bind the federal courts that hear California tax cases, allowed the charitable deduction for the excess in *Estate of Petter* (2011). How the clause is worded decides the case. The Fifth Circuit held a family to the appraiser’s number in *Nelson* (2021) because the clause pointed to an appraiser instead of the value “as finally determined for federal gift tax purposes,” and said nothing about where excess units would go.

**$15M**

Gift and estate tax exemption per person in 2026, Rev. Proc. 2025-32

**40%**

Tax rate on gifts above the exemption, IRC § 2001(c)

**$920,340**

Gift tax each spouse owed for 2009 in *Nelson* after the formula failed (5th Cir. 2021)

**$6,939,597.53**

Gift tax deficiency the IRS determined against each spouse in *Hendrix*, and the formula clause held (Tax Court 2011)

## What a valuation fight does to a large gift

A closely held interest has no market price, so the appraisal is an opinion and the IRS can audit the gift years later. Suppose a parent with $5,000,000 of exemption left plans to give $5,000,000 of nonvoting units in a family LLC to a trust for the children. The appraiser says $1,000 a unit, so the gift is 5,000 units. Three years later the IRS audits and the value is finally determined at $1,400 a unit. The numbers are hypothetical, not any family’s. If the gift was a fixed number of units, the parent owes $800,000 of gift tax. If it was written as a properly drafted Wandry or Petter clause, the parent owes nothing.

| Step | Fixed units | Nelson-style | Wandry clause | Petter spillover |
| --- | --- | --- | --- | --- |
| Units the trust receives | 5,000.00 | 5,000.00 | 3,571.43 | 3,571.43 |
| Units that move after the audit | 0 | 0 | 1,428.57 back to the parent | 1,428.57 to the charity |
| Gift to the family trust at $1,400 a unit | $7,000,000 | $7,000,000 | $5,000,000 | $5,000,000 |
| Charitable deduction | $0 | $0 | $0 | $2,000,000 |
| Taxable gift above the $5,000,000 intended | $2,000,000 | $2,000,000 | $0 | $0 |
| Gift tax at 40% | $800,000 | $800,000 | $0 | $0 |

A fixed gift of 5,000 units turns out to be a $7,000,000 gift, and the extra $2,000,000 is taxed at 40%. A clause that ties the gift to an appraiser’s number, as the one in *Nelson* did, gets the same result, because the appraiser’s number fixed the units. Under a Wandry clause the trust’s share drops to 3,571.43 units and the other 1,428.57 never left the parent. Under a Petter clause the trust also ends up with 3,571.43 units, and the 1,428.57 go to the charity, which yields a $2,000,000 charitable deduction. The Wandry result keeps the value in the family, but it has only Tax Court support and the IRS has said it won’t follow it.

## A Wandry clause defines the gift in dollars

A Wandry clause transfers “a sufficient number of” units so that their fair market value “for federal gift tax purposes” equals a stated dollar amount, so the gift doesn’t grow past the exemption the donor meant to use. It adjusts the number of units if the IRS or a court finally determines a different value. The Tax Court held that valid in *Wandry v. Commissioner*, T.C. Memo. 2012-88.

The Wandrys gave each of their four children $261,000 of membership units in Norseman Capital, LLC and each of five grandchildren $11,000, a total of $1,099,000 from each spouse. Their appraiser put a 1% interest at $109,000. The IRS audited, said the units were worth more, and issued deficiency notices treating the gifts as fixed percentages. The Tax Court held that each child was always entitled to about a 1.98% interest, the number of units worth $261,000 at the value the parties agreed on, so no gift exceeded the exemption the parents meant to use. The fix ran through the company’s capital accounts: the excess units were treated as never having left the parents.

People use “Wandry clause” for the defined value clause where the excess stays with the donor and no charity is involved.

## Why a definition survives when a take-back doesn’t

Every formula clause is trying to solve the same problem: a closely held interest has no market price, the appraisal is an opinion, and the IRS can audit the gift years later, so the question is what happens to the extra value when the IRS wins.

A savings clause, which undoes the taxable part of a gift and returns it to the donor, is void as against public policy. In 1939 Frederic Procter put remainder interests in two family trusts into a new trust for his children. The deed said that if a federal court of last resort ever decided any part of the transfer was subject to gift tax, that part “shall automatically be deemed not to be included in the conveyance” and would stay his. The Fourth Circuit called this a condition subsequent and held it void as contrary to public policy (*Commissioner v. Procter*, 142 F.2d 824 (4th Cir. 1944)). It discouraged collection, because any attempt to collect the tax would defeat the gift. It made courts decide a moot case. And it turned a court’s judgment into a nullity, because the judgment itself would undo the gift it ruled on.

A properly drafted defined value clause is treated as a definition of the gift, so *Procter* doesn’t reach it. The Tax Court put it this way in *Petter*, as quoted in *Wandry*: a savings clause is void because the donor tries “to take property back,” while a formula clause “merely transfers a ‘fixed set of rights with uncertain value’.” In a defined value clause the gift is complete on the day it’s signed. The only unknown is the value of a unit on that date, and that value never changes. An audit only finds it. That reasoning carried *McCord*, *Christiansen*, *Petter*, *Hendrix* and *Wandry*.

No federal appeals court has decided the public policy question for a gift. In both *McCord* and *Petter* the IRS argued public policy in the Tax Court and then dropped it on appeal, so neither the Fifth Circuit nor the Ninth Circuit ruled on it. The Eighth Circuit did reject the IRS’s policy argument in *Christiansen*, a disclaimer case. On public policy for gifts, the decisions in the taxpayer’s favor are Tax Court decisions.

Two other formula devices appear in other settings, sales and disclaimers at death. A price adjustment clause in a sale, which makes the buyer owe a higher price for the same shares, was upheld in *King v. United States* (10th Cir. 1976), as the Tax Court described it in *Petter*, though the IRS rejected it in Rev. Rul. 86-41, as *Petter* also describes. A formula disclaimer, which sends the disclaimed excess to charity at death, was upheld in *Estate of Christiansen* (8th Cir. 2009).

## Sending the excess to charity

*McCord* shows that a later event can’t change the shares. The McCords assigned their partnership interests by dollar amounts: $6,910,932.52 of value to their sons and the sons’ trusts, less assumed transfer taxes, $134,000 to an orchestra, and the rest to a community foundation. A divided Tax Court used a later agreement among the donees to fix the shares. The Fifth Circuit reversed, holding that a gift is valued on the date it’s made and later events are off limits, and it let the values on the McCords’ returns stand (*Succession of McCord v. Commissioner*, 461 F.3d 614 (5th Cir. 2006)).

*Christiansen* is the Eighth Circuit’s disclaimer case. Helen Christiansen’s daughter disclaimed everything above $6.35 million “as finally determined for federal estate tax purposes,” and 25% of the disclaimed amount passed to a charitable foundation. After the IRS forced a higher value, the court allowed the larger charitable deduction. It held that a valuation dispute about the date of death isn’t a future contingency (*Estate of Christiansen v. Commissioner*, 586 F.3d 1061 (8th Cir. 2009)).

In *Petter*, the Ninth Circuit case, the IRS’s audit moved extra units to the foundations and the court allowed the deduction. Anne Petter put about $22.6 million of UPS stock into an LLC, then gave and sold units to trusts for her children. The clauses assigned the trusts units worth a stated dollar amount, such as $4,085,190 “as finally determined for federal gift tax purposes” for one sale, with the rest to two community foundations. After the IRS audit, the parties settled on $744.74 a unit, up from the appraised $536.20, which moved 4,503.82 more units to one foundation and 237.04 to the other. The Ninth Circuit held the extra charitable gifts weren’t subject to a condition precedent and allowed the deduction (*Estate of Petter v. Commissioner*, 653 F.3d 1012 (9th Cir. 2011), after the Tax Court’s 2009 decision).

The charity has to be a real party, and *Hendrix* shows what that looks like: the foundation had its own counsel, a second appraisal and real bargaining power. A Texas couple assigned nonvoting stock in their company so that trusts for their daughters received stock worth stated dollar amounts and a donor-advised fund at a community foundation received the rest. The IRS determined a $6,939,597.53 deficiency against each spouse and argued the clauses weren’t made at arm’s length. The court held the clauses valid (*Hendrix v. Commissioner*, T.C. Memo. 2011-133). In *Petter* the foundations likewise negotiated changes and insisted on becoming full members of the LLC with voting rights. A charity that’s only a passive accommodation party doesn’t hold up.

The Tax Court denied the deduction in *Estate of Moore*, where whether the charity would get anything depended on a future audit. Howard Moore’s irrevocable trust told its trustees to send, through his living trust to a charitable trust, an amount equal to the value of any trust asset included in his gross estate, so more would pass to charity if the IRS won an audit. The court denied the deduction. In *Christiansen* and *Petter* the charity was sure to receive something and only the value was open. Here, whether the charity would get anything depended on a future audit and its outcome (*Estate of Moore v. Commissioner*, T.C. Memo. 2020-40).

## Without a charity, a Wandry clause rests on the Tax Court

The Wandrys had no charity. The court applied *Petter*‘s reasoning and held the excess units never left the parents. The IRS published its nonacquiescence in Internal Revenue Bulletin 2012-46, which means it generally won’t follow the decision in other taxpayers’ cases. No federal appeals court has approved a Wandry clause without a charity, so the version that keeps the value in the family carries more risk than the charity version.

## How Nelson turned on the drafting

Mary Pat and James Nelson thought they had written a Wandry clause, and each spouse paid $920,340 of gift tax for 2009 on value they believed it protected. The Fifth Circuit read the words they used, and two differences decided the case.

Mary Pat Nelson transferred limited partner interests “having a fair market value of” $2,096,000 by gift and $20,000,000 by sale, with the gift clause adding “as determined by a qualified appraiser within ninety (90) days” and the sale clause allowing 180 days. The appraiser’s numbers produced 6.14% and 58.65% interests. The Tax Court valued those interests at $2,524,983 and $24,118,933, and each spouse owed $87,942 of gift tax for 2008 and $920,340 for 2009. The Fifth Circuit affirmed in 2021 (*Nelson v. Commissioner*, 17 F.4th 556), after the Tax Court’s 2020 decision.

The clauses in *Petter*, *Christiansen* and *Wandry* tied the gift to value as finally determined for federal gift or estate tax purposes, and *McCord* and *Hendrix* used the willing-buyer, willing-seller test from the regulations. The Nelsons tied it to value “as determined by a qualified appraiser,” so once the appraiser spoke, the percentages were fixed and a later court valuation couldn’t change them.

Nothing in the Nelsons’ documents told anyone what to do with excess units. The court pointed out that every other formula case had language sending excess units somewhere, to a charity or back to the donor. The Nelsons’ documents had none, and the family’s own later reshuffling of units after the audit didn’t count, because events after the gift are off limits under *McCord*. The court also refused to read in the Nelsons’ tax-saving intent, because Texas contract law looks to the words, not to what the parties meant to say. A clause copied from a form that says the value will be “as determined by” a named appraiser, with nothing about where extra units go, is the clause the Nelsons signed. Other techniques that fail on a technicality are collected on [estate planning strategies that backfire](https://ridleylawoffices.com/estate-planning-strategies-that-backfire/).

## A clause that holds up measures value correctly and says where the excess goes

Give a dollar amount of value, not a unit count or a percentage. Describe the units as the number whose fair market value “as finally determined for federal gift tax purposes” equals that amount, or use the willing-buyer, willing-seller definition from Treas. Reg. § 25.2512-1. Don’t tie the value to a named appraiser or a deadline.

Say where excess units go and where a shortfall comes from. *Petter* had reallocation clauses running both ways between the trust and the charity. *Wandry* adjusted the number of units “in the same manner as” a formula marital deduction. *Nelson* had neither and lost. Don’t write it as a reversion either. Language that hands property back to the donor if a court finds tax due is the *Procter* clause, and it has been void since 1944.

If a charity takes the excess, make it a real, independent party. In *Hendrix* the foundation had its own counsel and a second appraisal, and in *Petter* the foundations negotiated changes and insisted on full member rights.

Keep the entity’s books consistent with the clause. In *Wandry* the IRS argued that the capital accounts showed fixed percentages. The court held the facts control the capital accounts, not the reverse, but a clean record avoids that argument. And get a full appraisal anyway. The clause protects against an error. It doesn’t replace a supportable value, and the same appraisal is what starts the IRS’s three-year clock on the gift tax return.

## The return has to report the dollar gift the document makes

Report a defined value gift as the dollar amount the document transfers, because reporting fixed percentages instead is what cost the taxpayers in *Knight*. In *Knight v. Commissioner*, 115 T.C. 506 (Tax Court 2000), the IRS won the formula issue. The transfer document gave each child’s trust the number of partnership units equal to $300,000. The Knights’ gift tax returns reported 22.3% interests instead, and at trial they argued the gifts were worth less than $300,000. The court disregarded the $300,000 figure, treated the gifts as 22.3% interests, and valued each at $394,515. In *Wandry* the schedules described the gifts as percentages too, but the returns reported the same dollar totals as the gift documents, and the court found no admission. Write the return so it matches the document from the start, and don’t report a fixed percentage and later argue a lower value.

The return also has to disclose the gift adequately, because it decides how long the IRS has to assess. Treas. Reg. § 301.6501(c)-1(f)(2) asks for a description of the property, the parties, the valuation method, any discounts, and for an entity interest valued from its assets, the value of 100% of the entity. Attaching an appraisal that meets § 301.6501(c)-1(f)(3) satisfies the valuation part. With adequate disclosure the IRS generally has three years to assess (IRC § 6501(a)). Without it, gift tax “may be assessed… at any time” (IRC § 6501(c)(9)). Attach a copy of the transfer document and say plainly that the gift is a formula transfer. The details are on [valuation discounts and adequate disclosure](https://ridleylawoffices.com/valuation-discounts-adequate-disclosure/), and the 2026 gift tax numbers are on [gift tax in 2026](https://ridleylawoffices.com/gift-tax-2026-california/).

## Where California changes the plan

A California donor gets the Ninth Circuit’s rule on the charity version and no appellate rule on the Wandry version. A California taxpayer who loses in the Tax Court appeals to the Ninth Circuit, and *Petter* is binding there on one point: excess units that pass to charity under a defined value clause qualify for the gift tax charitable deduction. The Ninth Circuit didn’t rule on *Procter*‘s public policy argument, because the IRS dropped it on appeal. A Wandry clause with no charity rests on a Tax Court memorandum opinion from a case that would have been appealed to the Tenth Circuit, and on the IRS’s stated refusal to follow it. That’s a real option, and it carries more risk than the charity version.

The operating agreement has to allow the transfer. Under Corp. Code § 17705.02, a person who receives a transferable interest in a California LLC gets distributions but can’t vote or take part in management unless admitted as a member, and a transfer that violates a restriction in the operating agreement “is ineffective as to a person having notice of the restriction” (§ 17705.02(f)). Before a formula gift, confirm the agreement permits transfers to the trust and any charity, admit them as members if that’s the plan, and decide how capital accounts will be adjusted if units move after an audit. See [assigning an LLC membership interest in California](https://ridleylawoffices.com/llc-membership-interest-assignment-california/) and [California LLC operating agreements](https://ridleylawoffices.com/california-llc-operating-agreement/).

Prop 13 still counts percentages. If the LLC owns California real estate, transfers of interests can be a change in ownership. Gaining control of more than 50% triggers reassessment under Rev. & Tax. Code § 64(c), and when the property went into the entity without reassessment under § 62(a)(2), transfers by the “original coowners” of “cumulatively more than 50 percent” trigger it under § 64(d). A change in ownership statement is due to the Board of Equalization within 90 days, from the entity under § 480.2 or from whoever acquires control under § 480.1, and missing it costs a 10% penalty (§ 482(b)). A defined value gift doesn’t tell you the final percentage until the audit period runs. The safer course is to keep cumulative transfers well under 50%, with room for an upward revaluation. That’s a planning judgment, not something a court has ruled on.

Community property adds a writing requirement and a basis cost. In *Hendrix* the couple signed a partition agreement turning their community stock into separate property before the gifts. In California that’s a transmutation and has to meet Fam. Code § 852(a): a written, express declaration by the spouse whose interest is affected. Under the statute that became § 852, the California Supreme Court held the writing has to state expressly that the character or ownership of the property is being changed (*Estate of MacDonald* (1990) 51 Cal.3d 262). Basis is the larger cost. A gifted unit takes the donor’s basis (IRC § 1015), while community property held until the first death can receive a new basis on both halves (IRC § 1014(b)(6)).

## Who needs a defined value clause

Defined value clauses matter when you’re giving or selling an interest that an appraiser has to value: LLC or partnership units, closely held stock, or a stake in a family company before a sale. They’re usually paired with a gift of the exemption, a sale to a grantor trust or a dynasty trust, and the same logic applies in a sale, where a higher value would otherwise turn part of the sale into a gift. *Petter*, *Hendrix* and *Nelson* all involved sales of units for a note alongside gifts. See how the techniques compare on [estate planning strategies compared](https://ridleylawoffices.com/estate-planning-strategies-compared/) and how family entities work on [family limited partnerships in California](https://ridleylawoffices.com/family-limited-partnership-california/).

I work alongside your CPA and, where the matter calls for it, co-counsel. Work at this level is built for each family and quoted in writing before any drafting starts.

## Working with Ridley Law

If you’re about to make a large gift of an entity interest, or you signed a formula clause and aren’t sure whether it reads like *Wandry* or like *Nelson*, the first call is free and runs 30 minutes, by phone or Zoom.

[Book my 30-minute call](https://ridley.click/eric-30) or call 805-244-5291.

## Frequently asked questions

### Is a Wandry clause valid in California?

Untested on appeal. No federal appeals court has approved a Wandry clause without a charity. The Tax Court upheld one in 2012, and the IRS has said it won’t follow that decision. The Ninth Circuit’s *Petter* decision supports the version that sends excess value to charity.

### What’s the difference between a defined value clause and a savings clause?

A defined value clause decides what was given on the day of the gift, a dollar amount of units. A savings clause gives a fixed amount and then takes part of it back if a court finds tax due. Courts have upheld the first and voided the second since *Procter* (1944).

### Do I need a charity in the clause?

No, but it changes the risk. With a charity, the excess passes to the charity and you get a deduction, and binding Ninth Circuit authority supports that. Without one, the excess stays with you under *Wandry*, which has only Tax Court support.

### How do I report a defined value gift on Form 709?

Report the dollar amount the document transfers, attach the transfer document and the appraisal, and describe the formula. Reporting fixed percentages instead is what cost the taxpayers in *Knight* (2000).

### Can a defined value clause be used in a sale to a trust?

Yes. *Petter*, *Hendrix* and *Nelson* all involved sales of units for a note alongside gifts. In a sale, the risk is that a higher value turns part of the sale into a gift, and the clause defines the units sold by value.

### Does a formula transfer of LLC units trigger Prop 13 reassessment?

It can if the LLC owns California real estate and the transfers give someone control or push the original owners’ cumulative transfers over 50% (Rev. & Tax. Code § 64(c), (d)). Plan the percentages with room for the value to be revised.

This page is general information about California and federal law as of its update date. It isn’t legal, tax, or investment advice for your situation, and reading it doesn’t create an attorney-client relationship.

**Related reading:** [valuation discounts and adequate disclosure](https://ridleylawoffices.com/valuation-discounts-adequate-disclosure/); [family limited partnerships in California](https://ridleylawoffices.com/family-limited-partnership-california/); [estate planning strategies compared](https://ridleylawoffices.com/estate-planning-strategies-compared/); [estate planning strategies that backfire](https://ridleylawoffices.com/estate-planning-strategies-that-backfire/); [ultra-high-net-worth estate planning](https://ridleylawoffices.com/ultra-high-net-worth-estate-planning-california/); [gift tax in 2026](https://ridleylawoffices.com/gift-tax-2026-california/).

Sources

- [U.S. Court of Appeals, 4th Cir., Commissioner v. Procter, 142 F.2d 824 (1944)](https://www.courtlistener.com/opinion/1551349/commissioner-of-internal-revenue-v-procter/) (1944-04-11)
- [U.S. Court of Appeals, 5th Cir., Succession of McCord v. Commissioner, 461 F.3d 614 (2006)](https://www.courtlistener.com/opinion/795532/succession-of-v-commissioner-of-internal-revenue/) (2006-08-22)
- [U.S. Court of Appeals, 8th Cir., Estate of Christiansen v. Commissioner, 586 F.3d 1061 (2009)](https://www.courtlistener.com/opinion/1381870/estate-of-christiansen-v-commissioner/) (2009-11-13)
- [U.S. Tax Court, Estate of Petter v. Commissioner, T.C. Memo. 2009-280](https://www.courtlistener.com/opinion/4560636/estate-of-petter-v-commr/) (2009-12-07)
- [U.S. Court of Appeals, 9th Cir., Estate of Petter v. Commissioner, 653 F.3d 1012 (2011)](https://www.courtlistener.com/opinion/222532/estate-of-petter-v-commissioner/) (2011-08-04)
- [U.S. Tax Court, Hendrix v. Commissioner, T.C. Memo. 2011-133](https://www.courtlistener.com/opinion/4561440/hendrix-v-commr/) (2011-06-15)
- [U.S. Tax Court, Wandry v. Commissioner, T.C. Memo. 2012-88](https://www.courtlistener.com/opinion/4561801/wandry-v-commr/) (2012-03-26)
- [U.S. Tax Court, Knight v. Commissioner, 115 T.C. 506 (2000)](https://www.courtlistener.com/opinion/4696538/knight-v-commissioner/) (2000-11-30)
- [U.S. Tax Court, Estate of Moore v. Commissioner, T.C. Memo. 2020-40](https://www.courtlistener.com/opinion/4743120/estate-of-howard-v-moore-virgil-l-moore-and-trustee-v-commissioner/) (2020-04-07)
- [U.S. Tax Court, Nelson v. Commissioner, T.C. Memo. 2020-81](https://www.courtlistener.com/opinion/4760196/james-c-nelson-v-commissioner/) (2020-06-10)
- [U.S. Court of Appeals, 5th Cir., Nelson v. Commissioner, 17 F.4th 556 (2021)](https://www.courtlistener.com/opinion/5294412/nelson-v-cir/) (2021-11-03)
- [IRS, Internal Revenue Bulletin 2012-46 (nonacquiescence in Wandry)](https://www.irs.gov/irb/2012-46_IRB) (2012-11-13)
- [IRS, Rev. Proc. 2025-32 (2026 exclusion amounts)](https://www.irs.gov/pub/irs-drop/rp-25-32.pdf) (2025-10-09)
- [U.S. Congress (via Cornell LII), 26 U.S.C. §§ 1014, 1015, 2001, 6501](https://www.law.cornell.edu/uscode/text/26/2001) (current)
- [Treasury (via Cornell LII), Treas. Reg. §§ 25.2512-1, 25.2522(c)-3, 301.6501(c)-1](https://www.law.cornell.edu/cfr/text/26/301.6501(c)-1) (current)
- [California Legislature, Corp. Code § 17705.02](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CORP&sectionNum=17705.02) (current)
- [California Legislature, Rev. & Tax. Code §§ 64, 480.1, 480.2, 482](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=64) (current)
- [California Legislature, Fam. Code § 852](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FAM&sectionNum=852) (current)
- [Supreme Court of California, Estate of MacDonald (1990) 51 Cal.3d 262](https://www.courtlistener.com/opinion/1218605/estate-of-macdonald/) (1990-08-09)

**Related reading:** [Defined Value Clause](https://ridleylawoffices.com/estate-planning-glossary-california/defined-value-clause/).