Monday, July 6, 2009
Wendy C. Gerzog (Baltimore) has posted Jorgensen: A Familiar FLP Story, 124 Tax Notes 79 (July 6, 2009), on SSRN. Here is the abstract:
Jorgensen [v. Commissioner, T.C. Memo. 2009-66 (March 26, 2009)] provides a common FLP story with a familiar conclusion. Under section 2036, the estate did not receive those coveted FLP discounts and paid taxes on the full value of the assets transferred to their FLPs. The court presents a careful, logical, and well-reasoned decision that should provide guidance in the FLP area to taxpayers.