January 29, 2013
Gerzog: Wimmer Wins FLP Annual Exclusions
In Wimmer [T.C. Memo. 2012-157], the Tax Court held that the income stream from a taxpayer’s gifts of family limited partnership interests was eligible for the annual exclusion. By comparing the income interest in the partnership’s dividend paying marketable securities to the income interest in a trust, the court made Wimmer a winner. But does the opinion logically lead to that conclusion?
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