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Limited partner or assignee interest: Tax Court sides with IRS

$225.00

SKU: ADVma191. Category: .

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Abstract: Wealthy taxpayers sometimes incorporate family limited partnerships (FLPs) in their estate plans to help minimize federal estate and gift taxes. Historically, the IRS has been aggressive in challenging such arrangements. This article summarizes a recent case in which the U.S. Tax Court sided with the IRS, offering a valuable reminder that, when it comes to the federal tax effect of intrafamily transfers of interests, labels aren’t determinative. Rather, the court will consider the substance of the transaction. A sidebar explains how the court handled valuation discounts. Estate of Streightoff v. Commissioner, T.C. Memo. 2018-178, Oct. 24, 2018

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