FLP lessons from the Hurford case

Prof. Wendy Gerzog (Professor of Law, University of Baltimore School of Law) has recently posted on SSRN her article entitled Hurford: FLP Practice Pointers.

Here is the abstract of her article:

Sometimes a case offers practice pointers: Hurford is one such case. Besides explaining what not to do (that is, what was actually done in the case), the Tax Court continually commented on what the decedent and her family might have done to improve their chances of success. The taxpayers in this case attempted to use family limited partnerships (FLPs) and a private annuity to reduce gift and estate taxes.