In our last edition, we reported on the United States District Court case Howard v. United States, in which a dentist with a professional corporation attempted to sell his practice and allocate most of the consideration to “personal goodwill.”
Tax litigation surrounding family limited partnerships is unending and we are delighted to report on two recent taxpayer victories.
The enormous tax dollars at stake in connection with valuation discounts for estate and gift tax purposes is evidenced by the never ending stream of family limited partnership cases.
The stream of family limited partnership litigation continues.
Many recent court decisions concerning family limited partnerships or limited liability companies (“LLCs”) have involved “bad facts making bad law.”
The wave of litigation over the efficacy of family limited partnerships has not abated.