Bigelow: The Ninth Circuit on FLPs
8 Pages Posted: 17 Dec 2007
The article discusses the Ninth Circuit's recent Bigelow case. The issues on appeal were: 1) whether the Tax Court erred in its finding that there was an implied agreement of income retention from the property the decedent transferred to her FLP, and 2) whether the Tax Court erred in its holding that the transfer did not constitute a bona fide sale for adequate and full consideration,exempting it from section 2036.
Keywords: FLP, estate planning, estate tax, section 2036, Bigelow, valuation, discount, bona fide sales
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