Check-the-Box Regs and Gift Tax Discounts

5 Pages Posted: 17 Feb 2010 Last revised: 26 Feb 2010

See all articles by Wendy C. Gerzog

Wendy C. Gerzog

University of Baltimore - School of Law

Date Written: February 16, 2010


This article discusses the recent Tax Court decision in Pierre and the effect for gift tax purposes of an entity’s classification made under the check-the-box regulations. The court was split on what those regulations mean when they state that an entity is to be disregarded ‘‘for federal tax purposes.’’

Keywords: FLP, family limited partnership, Pierre, check-the-box, lack of marketability discount, minority discount, gift tax

Suggested Citation

Gerzog, Wendy C., Check-the-Box Regs and Gift Tax Discounts (February 16, 2010). Tax Notes, Vol. 126, No. 7, 2010. 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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