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Abstract

Three recent Tax Court cases have provided significant insights into the treatment of family limited partnerships. While the Internal Revenue Service took an aggressive stance in challenging family limited partnerships or FLPs in 1997 and 1998, particularly where the only purpose behind the formation of a family limited partnership was to depress asset values with nothing of substance changed as a result of the formation, the recent cases have focused on the possibility of a gift on formation of the FLP and on whether a business purpose must be shown for a FLP to be recognized for tax purposes if properly formed under state law.

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