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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.

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 ...

Tax Court Upholds Estate's Fractional Discount for Minority Interest Held by Limited Partnership

This valuation dispute arose from the undivided real estate interest held by the Forbes QTIP trust.

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