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Family Limited Partnership

Decedent’s lifetime transfers of residence and rental properties includible in her estate

Decedent’s lifetime transfers of residence and rental properties includible in her estate

In Estate of Trombetta v. Commissioner, TC Memo 2013-234, the Tax Court has ruled that a taxpayer’s lifetime transfers of her residence to one trust and rental properties to another trust were transfers with a retained life estate and thus the properties were includible in her gross estate. It also ruled against the taxpayer with […]

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Court finds FLP was formed despite incomplete documents and awards big refund to estate

Court finds FLP was formed despite incomplete documents and awards big refund to estate

The Court of Appeals for the Fifth Circuit, affirming a district court, has determined in Thomas Lane Keller, et al., v. U.S. (CA 5th Cir., 2012) (a complete copy of the opinion is here), that a decedent capitalized a family limited partnership (FLP) before her death, notwithstanding that she hadn’t completed certain documents. This resulted […]

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Cases of Interest: Real Estate Transferred to Family Limited Partnership Escapes “Inclusion in Estate under Consideration” Exception

Cases of Interest:  Real Estate Transferred to Family Limited Partnership Escapes “Inclusion in Estate under Consideration” Exception

In a case involving an asserted estate tax deficiency of over $2.5 million, the Tax Court has held in Estate of Joanne Harrison Stone, TC Memo 2012-48, that real estate transferred to a family limited partnership (FLP) did not have to be included in the transferor’s gross estate under Code Sec. 2036 because the transfer […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney