Goodbye averages, hello analyses – Supporting FLP discounts isn’t getting any easier
Abstract: A difficult task to begin with, supporting discounts for family limited partnerships (FLPs) isn’t getting any easier. More specifically, judges are looking beyond the magnitude of discounts to examine precisely how appraisers are arriving at their opinions. This article provides some legal cases in point and goes on to explain what makes for a well-supported FLP discount. Citations: Peracchio v. Commissioner, T.C. Memo 2003-280. Berg v. Commissioner, T.C. Memo 1991-279.