angka917

Estate of Powell: Stranger Than Strangi and Partially Fiction

IRC Section 2036(a)(2) causes FLP to wash along the shores of the lacuna.

In Estate of Powell,1 issued on May 18, 2017, the U.S. Tax Court determined that cash and marketable securities transferred into a family limited partnership (FLP) under a power of attorney (POA) approximately one week before the taxpayer’s death were includible in the taxpayer’s gross estate under Internal Revenue Code Section 2036(a)(2). While the bad facts surrounding the transaction make this result unsurprising, the decision is notable because it

All access premium subscription

Your subscription will include 12 months of Trusts & Estates magazine and access to premium content on WealthManagement.com.

Hide comments

Comments

  • Allowed HTML tags: <em> <strong> <blockquote> <br> <p>

Plain text

  • No HTML tags allowed.
  • Web page addresses and e-mail addresses turn into links automatically.
  • Lines and paragraphs break automatically.
Publish