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Miller: Effective FLP Line Drawing

Wendy C. Gerzog

University of Baltimore - School of Law

September 21, 2009

Tax Notes, Vol. 124, No. 12, 2009

Miller is a decision on family limited partnerships (FLPs) with effective line drawing. The case is particularly helpful to distinguish the types of investment activities that constitute an acceptable nontax purpose under the Bongard criteria. The opinion further provides some guidelines on the factors of age, health, and FLP payment of estate tax liabilities to determine the applicability of section 2036 and its bona fide sales exception.

Number of Pages in PDF File: 4

Keywords: FLP, family limited partnership, estate tax, Miller, section 2036, bona fide sales exception, discounts

JEL Classification: H2, H29, H20, K34

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Date posted: October 12, 2009  

Suggested Citation

Gerzog, Wendy C., Miller: Effective FLP Line Drawing (September 21, 2009). Tax Notes, Vol. 124, No. 12, 2009. Available at SSRN: https://ssrn.com/abstract=1476207

Contact Information

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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