Surviving a section 2036(a)(2) attack

Article Abstract:

The provisions of Section 2036(a)(2) and its regulations are highlighted where two prominent cases such as 'Strangi' and 'Byrum' are distinguished. A checklist is provided to the practitioners to avoid the application of Section 2036(a)(2) to the inclusion of FLP assets in the estate of the transferor.

Taxes, Taxation, Partnership distributions

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It ain't over 'til it's over

Article Abstract:

A detailed description of the case of tax return against Harbor Cove Marina Partnership (HCMP) is presented. Suggestions for tax return auditing are also presented concluding that a partnership cannot be over until the final tax settlement is over.

Analysis, Company legal issue, Cases, Tax auditing, Tax audits, Tax returns, Tax compromises

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