Responding to IRS attacks on family limited partnerships
Article Abstract:
Family limited partnerships can continue to be useful planning tools after 1997 if estate planners use due diligence in planning and reviewing existing partnerships and they are properly operated and documented. The IRS struck at family limited partnerships with 5 Technical Advice Memoranda addressing valuation discounts. Whether the IRS position will hold up in light of 1997 Tax Court cases does not diminish tax planners' responsibility to take all contingencies into account.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1998
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Passing IRS scrutiny of a family limited partnership
Article Abstract:
Proper planning is needed to create a family limited partnership (FLP) which will pass muster with the IRS and receive the desired tax advantages. Both state and federal laws should be observed in creating an FLP and family members must meet partner recognition criteria. Relevant factors such as timing of formation and the ability to meet business purposes standards must also be considered.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1997
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Discounts are dead: a second look at A. Strangi Est
Article Abstract:
The authors discuss the tax consequences to family limited partnerships following the US Tax Court's decision in Estate of Strangi.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2001
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