Tax Court calculates its own values in FLP case

Description

Abstract: In recent years, the U.S. Tax Court has heard its share of cases challenging the legitimacy of family limited partnerships (FLPs). In early 2008, though, it was presented with an FLP case in which the IRS merely challenged the taxpayer’s valuation. The court in Astleford v. Commissioner ultimately decided to pick and choose from the opposing experts’ conclusions to calculate its own values. This article explains how the court arrived at its numbers and what it could mean for taxpayers.