This PodCast reviews the step transaction doctrine and where the line is drawn when we deal with the application of the step transaction doctrine in the formation of a family limited partnership. The IRS attempted to use their victory in the Senda case to get the same result in Holman v. Commissioner, 130 TC No. 12. But in an opinion that reminds us of the importance of the facts of the specific case in question, the Tax Court refused to take that step.
Materials for this week's podcast can be downloaded from http://edzollars.com/2008_06_09_Holman.pdf. Be sure to also look at the commentary of Owen Fiore, Paul Hood, and Jeff Pennell in our LISI Estate Planning archives. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com
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