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RABY BROS. REVIEW IMPLICATIONS OF BONGARD

March 28, 2005

Thanks to the excellent arrangement between the TaxProf and Tax Analysts, the Raby's analysis of the Bongard Tax Court case on family limited partnerships (FLPs) is now available to all. You may read it here (pdf format). From the Raby article:

The family limited partnership does offer great
opportunities for preventing family net worth from
splintering, including some degree of asset protection.
In the process, it also offers the opportunity of
transfer tax discounts. If the discounts are all that
is being sought, however, and it appears that the decedent
merely moved the assets into the partnership and nothing
more, little is apt to be accomplished taxwise. There is
a message in all this: Practitioners need to review
not only the basic estate planning strategy but also
periodically review its implementation. The tax devil
often lurks in the details. And that is not true of FLPs
alone.

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