Valuation Discounts With FLPs/LLCs: Where Are We Now? — 2.5 Missouri General Credits

This 2.1-hour September 24, 2007 presentation by John W. Porter, Esq., provides you with a comprehensive and useful explanation of the current status of IRS attacks on valuation discounts claimed with FLPs and LLCs, the taxpayers' responses and important cases. Mr. Porter, who is a partner in the Houston, Texas law firm of Baker & Botts, is considered by many to be the leading expert on this subject.

Topics include:

Overview

• define bundle of rights

• value thereof

• why IRS attacks entities

• Murphy argument

• gift on formation argument

IRC Section 2036(a)(1)

• Bigelow

• Korby

• Strangi

• Thompson

IRC Section 2036(a)(2)

• Strangi

• Kimbell

• Cohen

Bona Fide Sale For Adequate And Full Consideration

Production Of Documents

Where Are We Now?

• IRS settlement guidelines

• Lappo, McCord, Peracchio

Defined Value Or Formula Transfers

If you need credits in multiple states you MUST click here before placing your order for important information.

Price: $42.00

Course approved for these credits (and Expiration Dates When Applicable):
If you need credits in multiple states you MUST click here
before placing your order for important information.

AK — 2 General Credits
AZ — 2 General Credits
CA — 2 General Credits
CO — 3 General Credits, Expires 12/31/11
FL — 2.5 General Credits, Course #86527, Expires 3/25/09
IL — 2 General Credits, (attorneys seeking IL credit must place their order from the Illinois page)
MO — 2 General Credits
MT — 2 General Credits
NM — 2.1 General Credits, taped 9/25/07
NV — 2 General Credits
OH — 2 General Credits, (attorneys seeking OH credit must place their order from the Ohio page)
PA — 2 General Credits, (attorneys seeking PA credit must place their order from the Pennsylvania page)
TX — 2 Self-Study General Credits
WA — 2 General Credits, Activity ID #189404
WV — 2.5 General Credits

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