Tax Update Blog: Permalink
« Previous · Tax Update Blog Home · Next »
MORE ON BOTCHED WORLDCOM ESTATE PLANNING
February 16, 2006
The TaxProf this morning features an analysis of the Senda case by Tax Analysts. The Senda taxpayer was a bit too casual in respecting the formalities of family partnership gifts of Worldcom stock to get the courts to go along.
Wendy C. Gerzog, the author of the Tax Analysts piece, sums it up:
Senda illustrates what happens when the taxpayers do not respect the formalities of an FLP as well as the required sequence of transfers and documentation. In fact, the Tax Court was uncertain whether the taxpayers' stock contributions "were ever reflected in their [own] capital accounts."27 Otherwise, the transfer will likely be construed as an indirect transfer of property to the taxpayers' children, thus denying the taxpayers those enviable discounts.
Links:
Bookmark: del.icio.us • Digg • reddit
Tax Updates
Subscribe to Tax Updates
The items included in the Tax Update Blog are informational only and are not meant as tax advice. Consult with your tax advisor to determine how any item applies to your situation.
Joe Kristan writes the Tax Update items, and any opinions expressed or implied are not neccesarily shared by anyone else at Roth & Company, P.C. Address questions or comments on Tax Updates to
Search Tax Updates
Friends and Neighbors
Economics Nerds
Hard-Core Tax Nerds
Gigablogs
Insurance Folk
Goners
Legislation
Tax Update Data Feeds
