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
Estate of Streightoff: An Unusual Decision On the Valuation of a Controlling Interest
The result turns on what was transferred.