Estate of Rector; Estate of Mirowski; Gross v. Comm'r; Holman v. Comm'r

In 2008, there were several important decisions regarding the inclusion of family limited partnerships (FLPs) in the estate of a decedent under Internal Revenue Code Section 2036 and the valuation of gifts of partnership interests. Together, these cases indicate: For the bona fide sale exception of IRC Section 2036 to apply, clients still need a legitimate non-tax purpose for forming the FLP. The

In 2008, there were several important decisions regarding the inclusion of family limited partnerships (FLPs) in the estate of a decedent under Internal Revenue Code Section 2036 and the valuation of gifts of partnership interests.

Together, these cases indicate:

  • For the bona fide sale exception of IRC Section 2036 to apply, clients still need a legitimate non-tax purpose for forming the FLP.
  • The more active management required for the assets of the partnership,

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