Rector v. Commissioner Analyzed

Steve R. Akers (Bessemer Trust, Dallas, Texas) has recently published his article entitled Rector v. Commissioner, TC Memo 2007-367, RPPT eREPORT (Feb. 2008).

Here is a summary of his article as posted on RPPT eREPORT:

The Tax Court finds an implied agreement under §2036 and applies the section to the assets contributed to the FLP rather than to the gifts of LP interests under a “single plan” analysis.