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IRS Wins FLP Case: Not All Timber Barons Are Teflon

Although we wish it were otherwise, taxpayers don’t always win FLP cases.  In fairness, the IRS ought to win a case from time to time, given that they’re usually the party making the decision to settle or litigate.  When the facts are as unfavorable to the taxpayer as they were in Estate of Malkin v. […]

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Substantial Win for “Buy and Hold” FLP – Murphy Oil Heirs Are Smiling (But the IRS Isn’t)

 It’s possible KYEstates readers are focused on the Paul-Grayson Senate race, or the Louisville mayoral race (see latest polls here, and here, respectively). If you want a break from politics, however, we can take you back to the normal state of things (i.e., all transfer taxes, all the time) with a report on a truly resounding taxpayer […]

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Timmberrr…Another Taxpayer FLP Win!

At KYEstates, we don’t want to hex ourselves, or taxpayers, but the fact is that we’re on a little bit of an FLP roll here and here. The good news for taxpayers continues with Estate of Shurtz, T.C. Memo. 2010-21 (Feb. 3, 2010). Even though the taxpayer showed up at the Tax Court with mixed […]

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Heirloom Stock + Predator Creditors = Family Limited Partnership Win for Taxpayer

KYEstates is pleased to share welcome news of a taxpayer win in Estate of Black v. Comm’r, 133 T.C. No. 15 (Dec. 14, 2009). Black involved (you guessed it) a family limited partnership, and prominently features all four Big Themes of estate planning: favored and disfavored Family members, really large amounts of Money, and correspondingly […]

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Good News (As Far As It Goes) For Self-Settled Asset Protection Trusts

PLR 200944002 (Oct. 30, 2009) is an interesting development at the intersection of estate planning and asset protection planning.  The widely accepted back story to the Letter Ruling is that it relates to Alaska asset protection trusts, a topic dear to the hearts of renowned T&E leader Jonathan Blattmachr and his brother Doug, who just […]

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