In a 2-1 split decision, a recent Court of Appeal agreed with the IRS that an FLP with holdings that consisted only of Dell corporation stock had no legitimate business purpose, but was primarily an estate planning device. The dissenting opinion disagreed stating that maintaining family control is a legitimate business purpose. If the underlying asset had not been a highly liquid, publicly traded stock, I might agree with the dissenting opinion, but I have to ask myself how some members of the … [Read more...] about 2nd Update – Valuation Discounts – Thomas H. Holman Jr. et ux. v. Commissioner; No. 08-3774 (7 Apr 2010)
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