The valuation principles articulated in Ahmanson are equally applicable to the valuation of interests in
family limited partnerships with voting stock being analogous to a general partnership interest in a
family limited partnership, and with nonvoting stock being analogous to a limited partnership interest.
Focus on Gifts Given Through
Family Limited Partnerships(2) Although the
family limited partnership is an innovative use of existing laws regarding limited partnerships, it should always be established for legitimate business and non-tax estate planning purposes.
Then, its alternate food groups, the
family limited partnership and tax return preparation, became dangerous to eat.
The use of a
family limited partnership as an estate-planning
Velis had been leasing the property and building since its recent sale to the Uy
Family Limited Partnership. The property sold for $2.4 million, according to the Whatcom County treasurer's office.
1060, 388, 754, 743, and 734 (the SSVS is not limited solely to these sections); determination of the value of a
family limited partnership; consequences of discharge of indebtedness pursuant to IRC Sec.
(2) Although the IRS has asserted that a taxable gift can arise upon the contribution of capital to a
family limited partnership, this argument was rejected where the partnership agreement allocated income and expenses on a pro rata basis based on the partners' contributions to the partnership.
In one of the scenarios, they demonstrated how gifting minority interests to the children, creating a
family limited partnership to hold business real property, and doing a sales-and-leaseback of the principle residence provided a savings of $2 million dollars in death taxes to the heirs of a family-owned business.
The property sold for $3,700,000 to Janosz
Family Limited Partnership of San Diego.
The
family limited partnership must pass the "assignment-of-income principle" test to be treated as such.