advertisement
Jul 1, 2008 12:00 PM
Tax Law Update
Partnership restrictions disregarded under IRC Section 2703. Estate-planning lawyers are buzzing about the Tax Court's recent decision on family limited partnerships, H. Holman, Jr., 130 TC 12 (May 27, 2008), because the court ignored commonly used restrictions on transfers of partnership interests for gift tax valuation purposes under Internal Revenue Code Section 2703.
In November 1999, Thomas and Kim Holman transferred about 70,000 shares of Dell stock to a limited partnership in exchange for general and limited partnership interests. A trust for their children contributed 100 Dell shares for limited partnership (LP) interests. Just one week later, they made a gift of LP interests to a custodial account for one of their daughters. A month later, custodial accounts for their other three children contributed Dell stock for LP interests. In January 2000 and January 2001, the Holmans made gifts of LP interests to the trust for their children.
Sign in to
view the full article
Not a subscriber?
Subscribe & Save
Get immediate access to Trust & Estates onlineSubscriber Benefits
Learn more about Trust & Estates magazine, online article access and our free enewsletters.
Topics of Interest
| Estate Tax | Donor Advised Funds |
| GSTs | Family Offices |
| Private Foundations | Life Insurance |
| 2010 Tax Act News | Industry Trends Surveys |
E-Newsletter Signup
Poll
Topics of Interest
| Estate Tax | Donor Advised Funds |
| GSTs | Family Offices |
| Private Foundations | Life Insurance |
| 2010 Tax Act News | Industry Trends Surveys |
E-Newsletter Signup
advertisement
T&E eNewsletters
Wealth Watch 
Wealth Watch is a free e-newsletter delivered twice a month with expert advice on wealth management from Trusts & Estates.
Latest from Wealth Watch
Tech. Review
Technology Review is a free monthly e-newsletter from Trusts & Estates and nationally renowned expert Donald H. Kelley. It is geared to keeping estate planning lawyers current on the latest tech news they can use.
Latest from Tech. Review
Philanthropy Tax Guide
Each month, Conrad Teitell reports on and analyzes as important tax development governing charitable contributions, including how to maximize the benefits and avoid the pitfalls.
Latest from Conrad Teitell
2011 Trust Glossary
Click here to download the 2011 Trust Glossary
50 Years Ago This Month
| 50 years ago, in May 1962, we featured articles such as: "Future of Canadian Trusteeship" by Arthur H. Mingay", "Training Trust Employees" by Ian M. Marr, "What is a Trust Officer?" by Eric J. Brown, and "Selling Services" by Donald I. Webb. |
Conrad Teitell's Guide to Tax Benefits For Charitable Gifts
Click here to view the most up to date guide (September 2011)
Press Releases
advertisement
advertisement
