FLP and FLLC updates – Taxpayers enjoy some important victories
Abstract: Family limited partnerships (FLPs) and family limited liability companies (FLLCs) have long been popular business and estate planning vehicles for transferring minority interests. The IRS has frequently challenged these vehicles. But two recent cases have shown that properly structured FLPs and FLLCs can withstand IRS scrutiny. This article summarizes these two cases, Estate of Mirowski and Astleford v. Commissioner, which provide valuable guidance on the type of facts that can support a taxpayer’s position.