Bigelow: The Ninth Circuit on FLPs

8 Pages Posted: 17 Dec 2007

See all articles by Wendy C. Gerzog

Wendy C. Gerzog

University of Baltimore - School of Law

Abstract

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

Suggested Citation

Gerzog, Wendy C., Bigelow: The Ninth Circuit on FLPs. Tax Notes, Vol. 117, No. 12, 2007. Available at SSRN: https://ssrn.com/abstract=1075002

Wendy C. Gerzog (Contact Author)

University of Baltimore - School of Law ( email )

1420 N. Charles Street
Baltimore, MD 21218
United States
410-837-4522 (Phone)

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