Hurford: FLP Practice Pointers

6 Pages Posted: 11 Feb 2009 Last revised: 23 Feb 2009

See all articles by Wendy C. Gerzog

Wendy C. Gerzog

University of Baltimore - School of Law

Date Written: February 10, 2009


Sometimes a case offers practice pointers: Hurford is one such case. Besides explaining what not to do (that is, what was actually done in the case), the Tax Court continually commented on what the decedent and her family might have done to improve their chances of success. The taxpayers in this case attempted to use family limited partnerships (FLPs) and a private annuity to reduce gift and estate taxes.

Keywords: family limited partnership, FLP, private annuity, Hurford, gift tax, estate tax, estate planning

JEL Classification: K34, H24, H26, H29

Suggested Citation

Gerzog, Wendy C., Hurford: FLP Practice Pointers (February 10, 2009). Tax Notes, Vol. 122, No. 6, 2009. Available at SSRN:

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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