Although family limited partnerships are basically a variant (in form more than substance) of the limited partnership,1 and are generally subject to taxation under the Subchapter K of the Internal Revenue Code as partnerships,2 family limited partnerships have acquired a reputation stemming from a perception of tax avoidance and tax sheltering as well as hurried and often careless planning and formation rather than a reputation as a business organizational structure driven by genuine business-related motives and careful planning. Accordingly, the level of scrutiny by the Internal Revenue Service has appeared to be elevated simply by their name and nature.



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