‘Classic’ FLP Case by Judge Laro Finds No §2036 Estate Tax Exception

Business Valuation UpdateVol. 12 No. 8
Legal and Court Case Update
August 2006

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1751 Carpentry Work
estate and gift taxation
Estate of Lillie Rosen v. CIR
T.C. Memo. 2006-115
June 1, 2006
US
Federal Court
United States Tax Court
Daniel D. Mielnicki
Laro

Summary

Classic case where Tax Court (Judge Laro) finds no §2036 estate tax exclusion for family limited partnership (FLP).

See Also

Estate of Lillie Rosen v. CIR

Full Text of Court Cases
June 1, 2006

The U.S. Tax Court applied a multifactor analysis to determine whether the objective facts indicated whether an FLP had a legitimate and substantial nontax purpose such that sec. 2036 did not apply to recapture the value of assets transferred to a family ...