Latest FLP Case Lists ‘Bad Facts’ to Avoid

Business Valuation UpdateVol. 15 No. 2
Legal and Court Case Update
February 2009
6733 Trusts, Except Educational, Religious, and Charitable
525920 Trusts, Estates, and Agency Accounts
estate and gift taxation

Estate of Hurford v. Commissioner
2008 WL 5203652 (U.S. Tax Ct.)
December 11, 2008
US
Federal Court
United States Tax Court
Gary R Shuler
[unnamed]
Holmes

Summary

Tax Court disallows FLPs based on numerous bad facts, including poor drafting, delayed funding, and exchange of founder’s interests for a private annuity from the minority owners.

See Also

Estate of Hurford v. Commissioner

Tax Court disallows FLPs based on numerous bad facts, including poor drafting, delayed funding, and exchange of founder’s interests for a private annuity from the minority owners.