Tax Law Update

Family limited partnership assets were included in a decedent's estate under Internal Revenue Code Section 2036(a)(1). Once again, the IRS has triumphed over a family limited partnership (FLP) this time in a fight over the estate of a war hero's widow, Estate of Erma V. Jorgensen v. Commissioner, T.C. Memo 2009-66 (March 26, 2009). Erma Jorgensen died in 2002, owning interests in two FLPs. The first,

David A. Handler, partner, and Alison E. Lothes, associate in the Chicago office of Kirkland & Ellis LLP | May 01, 2009

Family limited partnership assets were included in a decedent's estate under Internal Revenue Code Section 2036(a)(1). Once again, the IRS has triumphed over a family limited partnership (FLP) — this time in a fight over the estate of a war hero's widow, Estate of Erma V. Jorgensen v. Commissioner, T.C. Memo 2009-66 (March 26, 2009).

Erma Jorgensen died in 2002, owning interests in two FLPs. The first, JMA-1, had been formed back in 1995 by Erma and her husband

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