5 Pages Posted: 29 Jan 2013
Date Written: January 28, 2013
In Wimmer, the Tax Court held that the income stream from a taxpayer’s gifts of family limited partnership interests was eligible for the annual exclusion. By comparing the income interest in the partnership’s dividend paying marketable securities to the income interest in a trust, the court made Wimmer a winner. But does the opinion logically lead to that conclusion?
Keywords: gift tax, family limited partnership, FLP, annual exclusion, trust, Wimmer
JEL Classification: H2, H20, H24, K34
Suggested Citation: Suggested Citation
Gerzog, Wendy C., Wimmer Wins FLP Annual Exclusions (January 28, 2013). Tax Notes, Vol. 138, No. 4, 2013. Available at SSRN: https://ssrn.com/abstract=2207854