Skip navigation

Estate of Streightoff: An Unusual Decision On the Valuation of a Controlling Interest

The result turns on what was transferred.

In Estate of Streightoff v. Commissioner,1 the Internal Revenue Service successfully argued that an interest in a family limited partnership (FLP) was a limited partner interest and not an assignee interest. In its decision, the Tax Court looked to the characteristics of the property transferred with consideration to substance over form as well as the admission requirements of the FLP agreement. In Streightoff, we also get an unusual decision on the valuation of a

All access premium subscription

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

Hide 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.