In this estate tax case, there were two issues: whether pursuant to IRC Sections 2035(a) and 2036(a), (b) the gross estate should have included: (1) shares Wayne Bongard (decedent) transferred to a holding company and (2) the holding company's membership ...
Estate of Bongard v. Commissioner
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Valid Nontax Purpose for Transfer to Holding Company Does Not Save Subsequent Transfer to FLP
This case does a good job of reviewing most of the significant decisions in this area and can serve as a minireference guide to the latest in FLP law.