Article on FLP and the Annual Gift Tax Exclusion

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?