Paul G. Marcotte, Jr., a partner in the Bethesda, Md. law firm of Paley, Rothman, Goldstein, Rosenberg, Eig & Cooper, Chtd., reports:
On Nov. 7, the U.S. Tax Court rejected the government's latest attempt to use Internal Revenue Code Section 2036 to disregard family partnerships in Estate of Stone v. Commissioner, T.C. Memo 2003-309. The decision may provide some clues to practitioners about how to structure these entities to avoid getting caught in the Service's anti-FLP d
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