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5th Circuit Affirms Tax Court’s Application of § 2036 to FLP Assets

In this last installment of the Strangi case, the 5th Circuit affirmed the Tax Court’s decision on remand that Strangi had retained enjoyment of the assets he had transferred to Strangi Family Limited Partnership (SFLP) and Stranco, Inc. through an implied agreement, and, thus, that the transferred assets were properly included in his estate under IRC Section 2036(a) for estate tax purposes.

Transfers of Stock to Business Trusts Not Included in Decedent’s Gross Estate

Schutt, I, Business Trust (Schutt I) and Schutt, II, Business Trust (Schutt II), both Delaware business trusts, were formed in 1998.

Estate of Strangi v. Commissioner (IV)

In this last installment of the Strangi case, the Fifth Circuit affirmed the Tax Court's decision on remand that Strangi had retained enjoyment of the assets he had transferred to Strangi Family Limited Partnership (SFLP) and Stranco, Inc.

Estate of Schutt v. Commissioner

Schutt, I, Business Trust (Schutt I) and Schutt, II, Business Trust (Schutt II), both Delaware business trusts, were formed in 1998.

Brief - Petitioner's Response to Brief For Respondent - Estate of Reichardt v. Commissioner

This is the taxpayer's response to the IRS brief in Estate of Reichardt v. Commissioner, a case involving a 36.46% limited partnership interest and IRC § 2036(a).

Brief - Petitioner's Opening Brief - Estate of Reichardt v. Commissioner

This is the opening brief filed by the taxpayer in Estate of Reichardt v. Commissioner, a case involving a 36.46% limited partnership interest and IRC § 2036(a).

Gross Estate Includes Date-of-Death Value of Assets Transferred to Family Limited Partnership

The issue in this case was whether decedent's gross estate included the value of interests in two family limited partnerships: the Thompson Turner Family Limited Partnership ("Turner Partnership") and the Thompson Family Limited Partnership ("Thompson Partnership").

Estate of Thompson v. Commissioner

The issue in this case was whether decedent's gross estate included the value of interests in two family limited partnerships.

Assets transferred to FLP part of estate

Prior to his death, decedent transferred his life interest in his residence, rental properties and other real properties, and investment accounts to the Reichardt Family Trust and Reichardt ...

Estate of Reichardt v. Commissioner

114 T.C. No. 9 UNITED STATES TAX COURT ESTATE OF CHARLES E. REICHARDT, DECEASED, WILLIAM D. REICHARDT, INDEPENDENT EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1224-98. Filed March 1, 2000. Decedent (D) had two children, C and W. On June 17, 1993, D formed a revocable family trust (the trust) and a family limited partnership (the partnership). The trust was the general partner of the partnership. D, C, and W were ...

Value of Assets Transferred to a Limited Partnership Is Included in Decedent’s Gross Estate

The Tax Court determined that the estate must include the value of partial interests in real property in its gross estate under IRC sec. 2036. The decedent owned interests and life interest in real property. He had the power to consume the property in w ...

Assets Controlled by Decedent After Transfer to FLP Part of Estate

Prior to his death, decedent transferred his life interest in his residence, rental properties and other real properties, and investment accounts to the Reichardt Family Trust and to Reichardt Partners Ltd., a family limited partnership of which the trust was the only general partner.

Wheeler v. United States

At issue is the plaintiff's claim that the government refused to allow a 10% minority discount on the value of stock in the estate, and taxed the value of decendant's homestead.

10% Minority Discount Accepted

A magistrate for the U.S. District Court for the Western District of Texas recommended a minority discount in addition to a lack of marketability discount when valuing a 50% interest in a closely held corporation. In deciding to apply the minority discoun ...

Wheeler v. United States

1995 U.S. Dist. LEXIS 21432 (W.D. Tex. Dec. 4, 1995). Judge Primomo.

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