Continuing IRS attacks on reality of pass-through entities

Business Valuation UpdateVol. 8 No. 4
April 2002
Owen G. Fiore, JD, CPA

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family limited partnership (FLP), due diligence, internal revenue service (IRS), internal revenue code (IRC), technical advice memoranda (TAM)

Summary

This article pulls together court cases, Field Service Advice (FSAs) and Technical Advice Memoranda (TAMs) that show the courts' and the IRS's positions on the valuations of interests in pass-through ...