Tax Court Rejects IRS Bid to Overrule Kerr

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June 30, 2000
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estate and gift taxation
estate tax, gift tax

Harper v. Commissioner
T.C. Memo. 2000-202, 2000 Tax Ct. Memo LEXIS 242
Federal Court
United States Tax Court


The issue in this estate tax matter is whether the provisions of the Limited Partnership Agreement for Harper Financial Co. LP the decedent and his two children entered into were "applicable restrictions" for purposes of IRC § 2704.

See Also

Harper v. Commissioner

At issue is whether, pursuant to section 2704(b), restrictions on the right to liquidate certain limited partnership interests in Harper Financial Co., L.P., should be disregarded.