New FLP Case: Taxpayer’s First Asset Transfer Merits Discount, But Not Second

Business Valuation UpdateVol. 15 No. 8
Legal and Court Case Update
August 2009

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6733 Trusts, Except Educational, Religious, and Charitable
525920 Trusts, Estates, and Agency Accounts
federal taxation
Estate of Miller v. Commissioner
T.C. Memo 2009-119, 2009 WL 1472208 (U.S. Tax Ct.)
May 27, 2009
US
Federal Court
United States Tax Court
Adria S Price, Mark D Eblen, Miriam R Price
Goeke

Summary

Court finds initial transfer of funds to FLP qualifies for exclusion from the estate at discounted value, but second transfer does not, for lack of bona fide business purpose.

See Also

Estate of Miller v. Commissioner

Full Text of Court Cases
May 27, 2009

Court finds initial transfer of funds to FLP qualifies for exclusion from the estate at discounted value, but second transfer does not, for lack of bona fide business purpose.