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Series

University of Baltimore Law

2011

FLP

Discipline

Articles 1 - 2 of 2

Full-Text Articles in Law

Flp Loss, But Crummey Win, Wendy G. Gerzog Nov 2011

Flp Loss, But Crummey Win, Wendy G. Gerzog

All Faculty Scholarship

In Turner the Tax Court determined that section 2036 applied to the decedent’s transfers of assets to his family limited partnership but that the insurance premiums he paid indirectly to his insurance trust qualified for the annual exclusion.


Linton Reversed: Indirect Gifts And The Step Transaction Doctrine, Wendy G. Gerzog Mar 2011

Linton Reversed: Indirect Gifts And The Step Transaction Doctrine, Wendy G. Gerzog

All Faculty Scholarship

The Ninth Circuit recently reversed the district court’s summary judgment in favor of the government in Linton on the issues of indirect gift and the applicability of the step transaction doctrine. The circuit court’s analysis focused on the taxpayers’ donative intent. With that emphasis, the Ninth Circuit remanded the case to the district court to determine the sequence of the relevant transactions.