Linton Reversed: Indirect Gift and the Step Transaction Doctrine

5 Pages Posted: 5 Apr 2011

See all articles by Wendy C. Gerzog

Wendy C. Gerzog

University of Baltimore - School of Law

Date Written: March 28, 2011

Abstract

The Ninth Circuit recently reversed the district court’s summary judgment in favor of the government in Linton on the issues of indirect gift and the applicability of the step transaction doctrine. The circuit court’s analysis focused on the taxpayers’ donative intent. With that emphasis, the Ninth Circuit remanded the case to the district court to determine the sequence of the relevant transactions.

Keywords: gift tax, FLP, family limited partnership, step transaction, indirect gift, Linton

JEL Classification: H20, K34

Suggested Citation

Gerzog, Wendy C., Linton Reversed: Indirect Gift and the Step Transaction Doctrine (March 28, 2011). Tax Notes, Vol. 130, No. 13, 2011. Available at SSRN: https://ssrn.com/abstract=1797597

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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