Wimmer Wins FLP Annual Exclusions

5 Pages Posted: 29 Jan 2013  

Wendy C. Gerzog

University of Baltimore - School of Law

Date Written: January 28, 2013

Abstract

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

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

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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