FLP Wars Update

For much of the last decade, the Internal Revenue Service has engaged in a frontal assault on the use of family limited partnerships (FLPs) and other closely held entities for estate-planning purposes. In its pronouncements, audits and litigation, the IRS has taken the position that an FLP can be disregarded for estate and gift tax purposes, notwithstanding the fact that the entity was valid under

John W. Porter | Jul 01, 2005

For much of the last decade, the Internal Revenue Service has engaged in a frontal assault on the use of family limited partnerships (FLPs) and other closely held entities for estate-planning purposes. In its pronouncements, audits and litigation, the IRS has taken the position that an FLP can be disregarded for estate and gift tax purposes, notwithstanding the fact that the entity was valid under state law.¹

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