FLP Formalities Should Be Respected in Order to Obtain Tax Advantages of the FLP

Business Valuation Update BVLaw
Legal and Court Case Update
July 12, 2004

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5015 Motor Vehicle Parts, Used
estate and gift taxation
Mark W. Senda and Michele Senda v. CIR (Senda I)
T.C. Memo. 2004-160
US
Federal Court
United States Tax Court
Daniel V. Conlisk, James R. Dankenbring, James Robert Loranger, Thomas C. Pliske
Cohen

Summary

The U.S. Tax Court determined that the limited partnership form should be disregarded for gift tax purposes when the contribution of property occurred on the same day as gifts of limited partnership units from the contributor to his children.

See Also

Mark W. Senda and Michele Senda v. CIR (Senda I)

Full Text of Court Cases
July 12, 2004

The U.S. Tax Court determined that the limited partnership form should be disregarded for gift tax purposes when the contribution of property occurred on the same day as gifts of limited partnership units from the contributor to his children and where the ...