FLP victory for IRS — but, taxpayer made it easy

On March 26, 2009, the Tax Court decided Estate of Jorgenson v. Commissioner, T.C. Memo 2009-66.  In this case, the court held that all assets of a family limited partnership were included in the decedent’s estate — a big victory for the IRS.

To read an excellent discussion of this case, see David Shulman, Estate of Jorgensen v. Commissioner: IRS wins another Family Limited Partnership Case due to the Taxpayer Doing Everything Wrong, South Florida Estate Planning Law Blog, March 27, 2009.