Estate planning

Article Abstract:

Beaty v. United States was a case wherein the Internal Revenue Service found itself in a position where it could not attach a lien on estate properties in order to collect estate taxes. It was suggested that the Sixth Circuit court wrongly interpreted section 6324(a)(2) of the Uniform Partnership Act. The section stipulates that tax liens can be applied to payment of the partnership's liabilities but not for liabilities of each partner.

Cases, Laws, regulations and rules, Transfer taxes, Tax liens

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Use of buy/sell agreements and life insurance in a partnership

Article Abstract:

Partnerships present certain conditions which must be considered in planning for ownership succession. A partnership offers more flexibility for owners to reach desired goals in ownership succession compared to corporations. Partnership agreements assure partners that their interests will be protected against outsiders while allowing for easy conversion of a deceased partner's investment from being a liquid asset into cash.

Usage, Finance, Life insurance, Buy-sell agreements

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Planning opportunities still exist for the liquidation of a deceased parther's partnership interest

Article Abstract:

Changes made to Sec. 736 by the Revenue Reconciliation Act of 1993 altered the structure and language of non-professional partnership agreements applied in cases when the partnership interest of a deceased partner have to be liquidated. However, despite such changes, a large degree of the planning flexibility offered by Sec. 136 is still available.

Methods, Analysis, Liquidation

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