Justifying FLPs

Since the early 1990s, use of the investment family limited partnership (FLP)1 as a sophisticated estate-tax reduction technique has grown. Almost universally, the Internal Revenue Service asserts in these situations that a valuation discount should not be permitted because the investment FLP has no real investment purpose and therefore no economic substance apart from estate-tax savings. The IRS

Since the early 1990s, use of the investment family limited partnership (FLP)1 as a sophisticated estate-tax reduction technique has grown. Almost universally, the Internal Revenue Service asserts in these situations that a valuation discount should not be permitted because the investment FLP has no real investment purpose and therefore no economic substance apart from estate-tax savings. The IRS employs this argument to pave the way for courts to be more liberal in their statutory

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