Family Entities

Closely-held businesses have been the backbone of job growth in this country, and it may well be that virtually all the net job growth during recent history was attributable to owner-operated businesses.

The Federal Court of Appeals for the Fifth Circuit (the "Fifth Circuit") has just reversed the United States District Court in Estate of Kimbell v. United States, 244 F. Supp. 2d 700 (2003).

In Strangi, the Tax Court eliminated all estate tax discounts for a family partnership. The authors note, it held, as it had in several prior. cases, that section 2036(a)(1) required this result. The court then went on to reach the…

The Strangi case has undergone a significant trip so far through the court system (and additional travel for it may arise). Estate of Strangi v. Commisioner, 115 TC 478 (2000)(“Strangi I”), aff’d in part and remanded in part, 293 F.3d 279…

In Estate of Strangi v. Commissioner, T.C. Memo 2003-145, the United States Tax Court held that the full fair market value, as of the date of the decedent's death, of the underlying assets of a family limited partnership in which the…

The value of property is a critical factor in estate planning. The value of certain partial interests is determined pursuant to actuarial tables. It is important to accurately determine these values because that will help determine whether…

When a client owns a "tax-sheltered" investment, the practitioner must deal with a number of tax and practical problems in planning and administering the estate. Several authorities consider the correct tax treatment of such investments to…