‘Classic’ FLP Case by Judge Laro Finds No §2036 Estate Tax Exception
Classic case where Tax Court (Judge Laro) finds no §2036 estate tax exclusion for family limited partnership (FLP).
Estate of Lillie Rosen v. CIR
The U.S. Tax Court applied a multifactor analysis to determine whether the objective facts indicated whether an FLP had a legitimate and substantial nontax purpose such that sec. 2036 did not apply to recapture the value of assets transferred to a family ...
Godwin v. Godwin
At issue is the valuation of the couple's window treatment business.