Elaine Gagliardi on Estate of Powell v. Commissioner and Grounds for Inclusion of Assets Transferred to a Family Limited Partnership

Analogizing to its earlier decision in Estate of Strangi v. Commissioner, the Tax Court in Estate of Powell v. Commissioner, after a long period of silence on the issue, resurrected and reinforced the applicability of I.R.C. Section 2036(a)(2) as grounds for inclusion of assets transferred to a family limited partnership.
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Analogizing to its earlier decision in Estate of Strangi v. Commissioner, the Tax Court in Estate of Powell v. Commissioner, after a long period of silence on the issue, resurrected and reinforced the applicability of I.R.C. Section 2036(a)(2) as grounds for inclusion of assets transferred to a family limited partnership.

Elaine Gagliardi earned her J.D. from the University of Montana School of Law and her LL.M in taxation from New York University. She is a professor of law at the University of Montana School of Law, where she teaches courses in business organizations and estate planning. She also continues to practice in the estate planning area with George Law Offices, Missoula, Montana. She previously practiced with Perkins Coie in Seattle and with Day, Berry & Howard in Hartford, Connecticut. Elaine is past chairperson of the Business, Estates, Trust, Tax and Real Estate Section of the State Bar of Montana. Professor Gagliardi is the update author of How to Save Time & Taxes Handling Estates and the co-author of Modern Estate Planning (Second Edition) (with Professors J. Martin Burke & Michael Friel).

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