Family Entities, 2036, and Powell
In this webinar, the panelists will analyze the Powell case and provide their insight on how it may impact estate planners advising existing family entities.
Browsing Tag
Strangi
Estate of Kimbell: Its Potential Effect on Strangi Type FLPs
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).
Strangi: A Critical Analysis and Planning Suggestions
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…
Avoiding the Strangi II Legacy for Old and New Partnerships
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…
The Potential Impact of the Estate of Strangi on Family Business Entities
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…
