FLP update – Court sides with IRS over bona fide business arrangements

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Abstract: Family limited partnerships (FLPs) offer advantages for some taxpayers, but the IRS continues to challenge these arrangements on several theories. This article summarizes one recent case, Holman v. Commissioner. In Holman, the Eighth Circuit Court of Appeals held that, because the FLP at issue didn’t satisfy the “bona fide business arrangement” requirement, its transfer restrictions shouldn’t be considered when calculating the valuation discount for shares of the FLP.