Holman rears its head again: Eighth Circuit holds that FLP transfer restrictions are disregarded under Internal Revenue Code Section 2703 — In 2008, the Tax Court held that gifts made by Thomas and Kim Holman would be respected as gifts of interests in their family limited partnership (FLP) rather than gifts of Dell stock transferred to the FLP. Holman v. Commissioner, 130 T.C. 170 (May 27, 2008). However, the Tax Court ultimately held that the transfer restrictions in the FLP agreement ...

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