Another Good-Facts Case Helps Deliver a Taxpayer Victory

The recent Tax Court case of Estate of Shurtz v. Commissioner provides an example of a good facts case that resulted in a taxpayer victory

When Mrs. Shurtz died in 2002, her 87.6% limited partnerships interest was valued at just over $6.1 million and her general partnership interest at $73,500. Because her estate plan disbursed nearly its total value – over $8.7 million – to qualified marital and other trusts, her estate claimed that no estate taxes were due.

 ...  the court found that the FLP “was carried out in the way that ordinary parties to a business transaction would do business with each other.”...  with no additional estate taxes due.

From an article on the website of Kotzin Valuation Partners, LLC.