Murphy v. U.S.
Taxpayer wins major, multi-million dollar victory for appraisal of FLP assets in estate tax case, including court’s adoption of substantial discounts for lack of control and lack of marketability.
Keller v. United States
Federal district court approves 47.5% combined discount for lack of marketability and lack of control for transfer of $250 million in FLP assets (investment bonds).
Latest FLP Case Lists ‘Bad Facts’ to Avoid
Tax Court disallows FLPs based on numerous bad facts, including poor drafting, delayed funding, and exchange of founder’s interests for a private annuity from the minority owners.
Estate of Hurford v. Commissioner
Tax Court disallows FLPs based on numerous bad facts, including poor drafting, delayed funding, and exchange of founder’s interests for a private annuity from the minority owners.
Tax Court Takes Novel Approach to DLOM Holding Period in Holman
U.S. Tax Court takes an unusual approach to DLOM, holding periods, in attack on family limited partnership.
Astleford Has It All: Latest Tax Court Case on FLP Discounts, Data, and More
In a lengthy opinion, the Tax Court considers the testimony of six appraisal experts, four for the taxpayer and two for the Internal Revenue Service.
Good News on FLP and LLC Planning—Appraisals Have Value!
Tax court upholds near-death transfers of family limited partnership.
Holman v. Commissioner (I)
U.S. Tax Court takes an unusual approach to DLOM, holding periods, in attack on family limited partnership.
Astleford v. Commissioner
Sure-to-be important Tax Court case focuses on FLP Discounts, 'tiered' discounts, REITs, and more.
Can You Take it With You? State Supreme Court
Kansas Supreme Court revisits Family Limited Partnership discounts case, and offers "contours of guidance."
Estate of Mirowski v. Commissioner
Tax court upholds near-death transfers of family limited partnership.
Another Bad Facts FLP—and Why Appraisers Should Care
What appraisers should know about another "bad facts" FLP.
In the Matter of the Estate of Norman B. Hjersted (II)
Kansas Supreme Court revisits Family Limited Partnership discounts case, and offers "contours of guidance."
Jelke Overruled: 11th Circuit Approves 100% Discount for Imbedded Capital Gains
11th Circuit rejects Jelke and adopts dollar-for-dollar discount for contingent capital gains tax liability.
Estate of Rector v. Commissioner
What appraisers should know about another "bad facts" FLP.
Litman a New Landmark Among Cases Considering Restricted Stock Discounts
Federal Court of Claims prefers option-pricing models to quantify marketability discounts for large block of restricted internet stock.
37% Discount Denied in Poorly Executed FLP
Court denies discount for family limited partnership in estate tax case where FLP made funds available to decedent and failed to observe partnership formalities and legitimate business.
Estate of Jelke v. Commissioner (II)
Eleventh Circuit rejects Jelke and adopts dollar-for-dollar discount for contingent capital gains tax liability.
IRS Burden of Proof Does Not Obviate Errors in Taxpayer Valuation
2nd Circuit rejects taxpayer’s contention that, should IRS fail its burden of proof, then the court must defer to estate’s valuation analysis.
Parties Unable to Settle Discount for Fractional Interest in Artwork
Finding that the estate failed to carry its burden to prove support for 35% discount in fractional (50%) interest in art, the court confirms IRS 5% discount.
Estate of Bigelow v. Commissioner (II)
Court denies discount for family limited partnership in estate tax case where FLP made funds available to decedent and failed to observe partnership formalities and legitimate business.
Two New Lottery Cases: The Odds of Discounting From Annuity Tables Decrease
6th Circuit finds that government annuity tables do not accurately reflect fair market value of lottery payments and continues case for expert evidence.