Wither the family limited partnerships: I think not!
Article Abstract:
Family limited partnerships came under attack by the IRS, the Tax Court, and the Clinton Administration in 1997 and 1998. Highly public advertisements by practitioners of the tax benefit value of such investment partnerships led to governmental scrutiny as well as abusive uses. The life of these partnerships is not likely long and practitioners should carefully plan and document the structuring of existing and newly created entities.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1998
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Toiling in King Solomon's mine: a study in business valuation for transfer tax purposes
Article Abstract:
Valuation of businesses for purposes of estate or gift taxes can be accomplished by reference to IRS Revenue Ruling 59-60 which provides practitioners with eight factually-based factors. Closely held business interests are particularly difficult to value. The Tax Court may reject valuations which are apparently consistent with IRS rules, as it has in several cases including Buffalo Tool & Die Manufacturing Co. v. Commissioner.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1998
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