The FLP Quadrilogy

Estate and gift tax valuation positions associated with family limited partnerships (FLPs) often are challenged by the Internal Revenue Service and somewhat unpredictably adjudicated by the courts. But in the last two years, taxpayers have won four key victories starting with the Mirowski case in 2008 and continuing with the Miller, Keller and Murphy cases in 2009 in which estates were able to prevail

Estate and gift tax valuation positions associated with family limited partnerships (FLPs) often are challenged by the Internal Revenue Service and somewhat unpredictably adjudicated by the courts. But in the last two years, taxpayers have won four key victories — starting with the Mirowski case in 2008 and continuing with the Miller, Keller and Murphy cases in 2009 — in which estates were able to prevail against the IRS challenges of FLPs because the bona fide sal

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