Family Limited Partnership

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…