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Moore IRC Section 2043 Issues for FLP Planning

Tax Court further explores the consequences of its holding in Powell.

For a period of time, Tax Court decisions regarding family limited partnerships (FLPs) had a familiar read to them. A typical FLP case involved an assertion by the Internal Revenue Service that the transferor retained rights to transferred property that were impermissible under Internal Revenue Code Section 2036(a)(1), and the defense would stand or fall on whether the transfer was a bona fide sale for full and adequate consideration. Case analysis largely focused on what worked and didn’t

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