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Article: Family limited partnerships: to qualify or not to qualify for the bona fide sale for full and adequate consideration exception under section 2036.
- Article from:
- Florida Bar Journal
- Article date:
- November 1, 2005
- Author:
CopyrightCOPYRIGHT 2005 Florida Bar. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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The last article written by the authors regarding family limited partner ships ("FLPs") for The Florida Bar Journal discussed Estate of Thompson v. Commissioner, T.C. Memo 2002-246. (1) The article focused on [section] 2036(a)(1) of the Internal Revenue Code of 1986, as amended, and the formation and operations of an FLP. Since Thompson, there have been a number of cases that have addressed FLPs and the issues relating to [section] 2036 of the Code, (2) and there have been many excellent articles published which discuss such cases and the "retained possession or enjoyment" of the transferred property test or "right to the income" from the transferred property test ...