Federal Court Clarifies When IRS Can Subpoena Appraiser’s Work File
9th Circuit confirms that IRS may subpoena appraiser’s work files when the taxpayers’ liability has not yet been “finally determined”—and also no privilege or protections when the report was prepared primarily to comply with tax laws.
United States v. Richey
Ninth Circuit confirms that IRS may subpoena appraiser’s work files when the taxpayers’ liability has not yet been “finally determined;” and also, no privilege or protections when the report was prepared primarily to comply with tax laws.
IRS and Taxpayer Agree to 35% DLOM—If FLP Transfers Pass ‘Indirect Gift’ Tests
Tax Court accepts stipulated 35% DLOM after finding that FLP funding and transfer is not an indirect gift.
Bianca Gross v. Commissioner
Tax Court accepts stipulated 35% DLOM after finding that FLP funding and transfer is not an indirect gift.
For Choosing Multiples & Comparables, the Data Really Do Matter
Court determines fair market value of limited partnership units in estate tax case, accepting net asset value and market approaches, with dispute focusing on measures and range of multiples for comparables ...
Valid Nontax Purpose for Transfer to Holding Company Does Not Save Subsequent Transfer to FLP
This case does a good job of reviewing most of the significant decisions in this area and can serve as a minireference guide to the latest in FLP law.
W.G. Anderson, et al. v. United States
Court determines fair market value of limited partnership units in estate tax case, accepting net asset value and market approaches, with dispute focusing on measures and range of multiples for comparables ...
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.