Family Limited Partnership Formed Two Days Before Death Not Sham Transaction

Business Valuation Update BVLaw
Legal and Court Case Update
January 18, 2000
0291 General Farms, Primarily Livestock and Animal Specialties
112990 All Other Animal Production
estate and gift taxation
income approach, discount for lack of marketability (DLOM), market approach, partnership agreement, discount for lack of control (DLOC), undivided interest

Church v. United States (I)
2000 U.S. Dist. LEXIS 714
Federal Court
United States District Court
Bruce Johnson (for plaintiff)


The primary issue in this estate tax refund action was whether Stumberg Ranch Partners Ltd. was formed for a bona fide business purpose, or was a sham transaction designed to avoid estate and gift taxes.

See Also

Church v. United States (I)

At issue is whether a partnership transaction was entered into for no purpose other than to reduce the taxation of Mrs. Church's estate.