Recent Cases Affecting FLPs and LLCs

Louis A. Mezzullo (Partner, Luce Forward) has written an article entitled Recent Cases Affecting FLPs and LLCs, 34 ACTEC 88 (Fall 2008).

Here is a summary of the article:

The IRS has challenged the use of family limited partnerships and family limited liability companies by attempting to include the assets of those entities in the gross estates of transferors under I.R.C. § 2036(a). This article considers and analyzes recent Tax Court cases in this area of the law. The article includes a discussion of a recent taxpayer victory in Estate of Mirowski v. Commissioner.