Summary
The U.S. Court of Appeals for the 8th Circuit determined that a transfer of public stock to a family limited partnership (FLP) made close in time to a gift of FLP interests was an indirect gift of the pro rata share of the public stock for gift tax purposes.
See Also
Mark W. Senda and Michele Senda v. CIR (Senda II)
The U.S. Court of Appeals for the Eighth Circuit determined that a transfer of publicly stock to a family limited partnership (FLP) made close in time to a gift of FLP interests was an indirect gift of the pro rata share of the public stock for gift tax p ...