Wandering Far Afield with Defined Value Clauses
Wendy C. Gerzog
University of Baltimore - School of Law
May 31, 2012
Tax Notes, Vol. 135, No. 9, 2012
The Wandry decision extends the application of defined value clauses beyond those family limited partnership cases that transfer any excess value to a charity. In Wandry, the Tax Court reads Procter narrowly and ignores the fundamental rationale of Robinette.
Number of Pages in PDF File: 6
Keywords: Defined Value Clauses, gift tax, family LLC, FLP, Wandry, Procter, Robinette
JEL Classification: K34, H20, H24Accepted Paper Series
Date posted: June 2, 2012
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