In the ongoing family limited partnership (FLP) battle between taxpayers and the Internal Revenue Service, taxpayers have been able to achieve some significant victories over the past two years in the Tax Court, particularly in the face of IRS challenges under Internal Revenue Code Section 2036(a). In these recent cases, the IRS has argued that all of the assets contributed by a decedent into an FLP during his lifetime should be included in the gross estate under a Section 2036(a) retained ...

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