Valuation Discounts for Gift of Single-Member LLC Interests

In a split decision by the U.S. Tax Court (Suzanne J. Pierre v. Comm., 133 T.C. No. 2), the court dealt with the issue as to whether a single-member LLC is to be disregarded for transfer tax purposes (i.e., gift tax purposes), thus treating the gift as a direct gift of the underlying property of …

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Step Transaction Doctrine

A recent case in the federal district court highlights the need to have some time elapse between the date of formation and funding of an FLP or FLLC and the date of gifting of interests in the FLP/FLLC. In Heckerman v U.S., the taxpayers (David and Susan Heckerman) took the following steps in gifting of …

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