Monday, January 28, 2013
Wendy C. Gerzog (Professor, University of Baltimore School of Law) recently published an article entitled, Wimmer Wins FLP Annual Exclusion, Vol. 138 Tax Notes, No. 4 (2013). Provided below is the abstract from SSRN:
In Wimmer, the Tax Court held that the income stream from a taxpayer’s gifts of family limited partnership interests was eligible for the annual exclusion. By comparing the income interest in the partnership’s dividend paying marketable securities to the income interest in a trust, the court made Wimmer a winner. But does the opinion logically lead to that conclusion?