Tax Court Finds 12% Minority Discount and 23% DLOM for Cash-Only FLP
In April 1999, Webster Kelley and his daughter and son-in-law (the Loudens) formed Kelley-Louden Business Properties LLC (KLBP LLC), and Kelley-Louden Ltd., a family limited partnership (KLLP).
Estate of Kelley v. Commissioner
In April 1999, Webster Kelley and his daughter and son-in-law ("the Loudens") formed Kelley-Louden Business Properties, LLC (KLBP LLC), and Kelley-Louden, Ltd., a family limited partnership (KLLP).
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.
Another FLP Bites the 2036 Bullet
In this estate tax case, the issue was whether the value of assets contributed to a family limited partnership (FLP) was includable in the decedent’s gross estate; the Tax Court held it was.
1st Circuit Affirms FLP Case Against Taxpayer
The 1st Circuit affirmed all aspects of a Tax Court determination unfavorable to the estate of Ida Abraham (the Estate).
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 Abraham v. Commissioner (II)
The First Circuit affirmed all aspects of a Tax Court determination unfavorable to the estate of Ida Abraham (the Estate).
Estate of Korby v. Commissioner
In this estate tax case, the issue was whether the value of assets contributed to a family limited partnership (FLP) was includable in the decedent's gross estate; the Tax Court held it was.
Estate of Bongard v. Commissioner
In this estate tax case, there were two issues: whether pursuant to IRC Sections 2035(a) and 2036(a), (b) the gross estate should have included: (1) shares Wayne Bongard (decedent) transferred to a holding company and (2) the holding company's membership ...
Tax Court displeased with all experts’ DLOC and DLOM analyses
The primary issues in this gift tax case were the appropriate discounts for lack of control and lack of marketability to apply to gifted and sold interests of a family limited partnership.
Court Uses Raw Data From Bajaj Study to Determine DLOM
The only issue in this case was the fair market value of gifted family limited partnership (FLP) interests.
Peracchio v. Commissioner
Issues were appropriate discount for lack of control and discount for lack of marketability to apply in valuing gifts of family limited partnership interests.
Lappo v. Commissioner
The issue for decision is the fair market value of interests in a family limited partnership that petitioner transferred in 1996.
Tax Court Accepts Negative Industry Risk Premium and Unique Combined Discount Matrix
The decedent, Helen Deputy, formed a family limited partnership comprised of 99% of a limited partnership interest retained by Deputy and two 0.5% general partnership interests, one held by Deputy and one held by her son.
Tax Court Rules on Remand That IRC Section 2036 Applies
The original Tax Court ruling in this case was Estate of Strangi v. Commissioner, 115 T.C. No. 35 (U.S. Tax Ct. Nov. 30, 2000).
Estate of Deputy v. Commissioner
Issue was the fair market value of a 19.99% interest of stock owned by an FLP, and court discussed negative industry risk premium and unique matrix for determining marketability discount.
Estate of Strangi v. Commissioner (III)
Issue on remand is whether the value of property transferred is includable in his gross estate pursuant to section 2036(a).
Continuing IRS attacks on reality of pass-through entities
This article pulls together court cases, Field Service Advice (FSAs) and Technical Advice Memoranda (TAMs) that show the courts' and the IRS's positions on the valuations of interests in pass-through ...
Full Tax Court addresses FLP issues in recent trilogy
Three recent U.S. Tax Court cases address important issues relating to the use of family limited partnerships for estate planning purposes, Shepherd v. Commissioner , decided Oct. 26, 2000, and K ...
Technical Advice Memorandum 9725002
PRIVATE RULING 9725002 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) of the Internal Revenue Code."
Technical Advice Memorandum 9730004
PRIVATE RULING 9730004 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) of the Internal Revenue Code."
Technical Advice Memorandum 199938005
PRIVATE RULING 199938005 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) o ...
FLP trilogy a victory for taxpayers
As discussed in my December 2000 Editor's Column, I requested that several members of our Editorial Advisory Board provide me with comments regarding the recent Tax Court trilogy of FLP cases for a sy ...
Partnership discount info in a click
Partnership Profiles Minority Interest Discount Database , Partnership Profiles, Inc. , (800) 634-4614, Available online or CD-ROM. $295. &nbs ...
The IRS and Family Limited Partnerships—Issues and Opinions
n The IRS and Family Limited Partnerships—Issues and Opinions , Clay, Kimberly E. BizVal.com , Vol. 11, No. 3, 1999. Kimberly Clay explains that even though the IRS allows discounts for mino ...
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