The Step Transaction Doctrine
(Professor of Law, University of Baltimore School of Law) has recently posted on SSRN her article entitled Linton Family LLC and the Step Transaction Doctrine, 125 Tax Notes 1027 (2009).
“This article discusses Linton, a district court decision about a family limited liability company, indirect gifts, and the step transaction doctrine. The moral of Linton v. United States is that disaster looms for achieving desired family entity discounts when all significant events are performed in one day, especially when they occur without meticulous care.”