Tax Court Rejects IRS Bid to Overrule Kerr v. Commissioner

Business Valuation UpdateVol. 6 No. 10
Legal and Court Case Update
October 2000
8111 Legal Services
541110 Offices of Lawyers
estate and gift taxation
estate tax, gift tax

Harper v. Commissioner
T.C. Memo. 2000-202, 2000 Tax Ct. Memo LEXIS 242
June 30, 2000
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, entered into by the decedent and his two children, 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.