FLP in the Black

5 Pages Posted: 19 Apr 2010  

Wendy C. Gerzog

University of Baltimore - School of Law

Date Written: April 19, 2010

Abstract

In Estate of Black, because the Tax Court held the Blacks' transfers fell within the bona fide sales exception of section 2036, they were successful at avoiding the application of the provision. Thus, they were able to obtain valuation discounts for their transfers of property (mostly marketable securities) to their son and grandchildren. The court also decided the marital trust funding valuation date issue in the executor's favor and allowed almost half of the claimed administrative expense deductions.

Keywords: estate tax, family limited partnership, FLP, section 2036, bona fide sales, marital deduction, administrative expense, section 2056, section 2053, valuation discounts, estate of Black

JEL Classification: H20, H24, H29, K34

Suggested Citation

Gerzog, Wendy C., FLP in the Black (April 19, 2010). Tax Notes, Vol. 127, No. 3, 2010. Available at SSRN: https://ssrn.com/abstract=1592128

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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