The Resurrection

As practitioners are acutely aware, the Internal Revenue Service has pursued a variety of arguments during the past decade to attack family limited partnerships (FLPs). The IRS has deployed Internal Revenue Code Sections 2036, 2701, 2702 and 2704, plus indirect gift arguments, as well as the business purpose and economic substance doctrines. (See Many Fronts, p. 22.) Recently, though, the Service

As practitioners are acutely aware, the Internal Revenue Service has pursued a variety of arguments during the past decade to attack family limited partnerships (FLPs). The IRS has deployed Internal Revenue Code Sections 2036, 2701, 2702 and 2704, plus indirect gift arguments, as well as the business purpose and economic substance doctrines. (See “Many Fronts,” p. 22.)

Recently, though, the Service resurrected arguments long thought dead. In Holman v. Commissioner,1

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