limited partnerships

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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Fisher v. U.S. – Taxpayers Denied Gift Tax Annual Exclusion for Gifts of LLC Interests

We’re never happy to report IRS wins at KYEstates, but if we have to bring you news of taxpayer defeat, we like it when the defeat breaks no new ground in favor of the government. KYEstates previously discussed the denial of the annual exclusion for gifts of limited partnership interests in Price, which was sort of [...]

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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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