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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