The document provides a comprehensive analysis of the use of Family Limited Partnerships (FLPs) and discount planning in estate tax cases. It includes a detailed examination of various court cases where the IRS challenged the application of discounts in FLP planning under Section 2036 of the Internal Revenue Code. The document discusses both 'IRS Friendly' and 'Taxpayer Friendly' cases, highlighting the legal arguments and court decisions. It also covers the future of valuation discounts, IRS appeals settlement guidelines, and the impact of the Byrum case on FLP planning.
documents/EFTA01126625.pdf
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