‘Sham’ Funding Plus Pledging FLP Assets for Personal Debt Adds Up to Taxpayer Loss

Business Valuation UpdateVol. 15 No. 12
Legal and Court Case Update
December 2009

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federal taxation
Estate of Malkin v. Commissioner
2009 WL 2958661 (U.S. Tax Ct.)
September 16, 2009
US
Federal Court
Federal
United States Tax Court
Edward L Peck, Frederick C Mutter, Gerald J Fields, Harvey A Strickon, Lydia A Branche, Shawna A Early
Halpern

Summary

Tax Court finds transfer of $16 million in marketable securities to two FLPs fail to qualify as bona fide, nontax business transactions when decedent retained full use of assets, including pledging them as collateral for personal debt.

See Also

Estate of Malkin v. Commissioner

Full Text of Court Cases
September 16, 2009

Tax Court finds transfer of $16 million in marketable securities to two FLPs fail to qualify as bona fide, non-tax business transactions when decedent retained full use of assets, including pledging them as collateral for personal debt.