Many Fronts

The Internal Revenue Service has almost literally thrown the (Internal Revenue Code) book at family limited partnerships (FLPs), seeking to negate their validity, and thereby knock out discounts and reap higher tax payments. It has had some of its greatest success against FLP discounts with IRC Section 2036(a).1 In Strangi II,2 the Tax Court's second ruling on Strangi,3 the IRS argued successfully

The Internal Revenue Service has almost literally thrown the (Internal Revenue Code) book at family limited partnerships (FLPs), seeking to negate their validity, and thereby knock out discounts and reap higher tax payments.

It has had some of its greatest success against FLP discounts with IRC Section 2036(a).1

In Strangi II,2 the Tax Court's second ruling on Strangi,3 the IRS argued successfully that the full value of an FLP's assets should be included

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