Transfers to FLP Included in Decedent’s Gross Estate for Estate Tax Purposes
Grant Thornton LLP
July 5, 2006
In Estate of Rosen v. Commissioner, T.C. Memo. 2006-115 (6/1/06), the Tax Court concluded that property transferred by a decedent’s revocable trust to a family limited partnership (“FLP”) was includible in the decedent’s gross estate under Sec. 2036(a)(1). In general, Sec. 2036(a)(1) includes in a decedent’s gross estate for estate tax purposes the value of transfers made by a decedent during his or her lifetime when the decedent has retained certain rights with regard to the possession of, enjoyment of or income from the transferred property.
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