Effective FLP Line Drawing

Family limited partnerships (FLPs) have become a staple of estate-tax planning.  Wendy C. Gerzog (Baltimore) has an article, Miller: Effective FLP Line Drawing, 124 Tax Notes 1273 (Sept. 21, 2009) (SSRN), that discusses a recent Tax Court opinion, Estate of Miller v. Commissioner, T.C. Memo. 2009-119.  Among other things, the opinion in Miller discusses when FLPs will be considered to have a non-tax purpose.

Gary Rosin

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