Check-the-Box Regs and Gift Tax Discounts

Abstract:     
This article discusses the recent Tax Court decision in Pierre and the effect for gift tax purposes of an entity’s classification made under the check-the-box regulations. The court was split on what those regulations mean when they state that an entity is to be disregarded ‘‘for federal tax purposes.’’

Number of Pages in PDF File: 5

Keywords: FLP, family limited partnership, Pierre, check-the-box, lack of marketability discount, minority discount, gift tax

Accepted Paper Series