Check-the-Box Regs and Gift Tax Discounts
5 Pages Posted: 17 Feb 2010 Last revised: 26 Feb 2010
Date Written: February 16, 2010
Abstract
This article discusses the recent Tax Court decision in Pierre and the effect for gift tax purposes of an entity’s classification made under the check-the-box regulations. The court was split on what those regulations mean when they state that an entity is to be disregarded ‘‘for federal tax purposes.’’
Keywords: FLP, family limited partnership, Pierre, check-the-box, lack of marketability discount, minority discount, gift tax
Suggested Citation: Suggested Citation
Gerzog, Wendy C., Check-the-Box Regs and Gift Tax Discounts (February 16, 2010). Tax Notes, Vol. 126, No. 7, 2010, Available at SSRN: https://ssrn.com/abstract=1553727
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