News & Events

HomeNewsBlogThe Darwinian Approach to Partnership Sustainability: Mirowski

The Darwinian Approach to Partnership Sustainability: Mirowski

Journal of Passthrough Entities
The partnership cases over the last 5 years (since what has become known as Strangi II, T.C. Memo.2003-145) have provided the tax planner with a reasonable roadmap as to how to structure sustainable partnerships for estate tax planning purposes. The cases established that the Tax Court is more than willing to apply a broad reading and liberal application of Code section 2036, meaning that it will apply 2036 to partnership cases to ignore the partnership for purposes of valuing partnership assets.



Contact us

Get In Touch

  • Please do not submit any confidential information using this contact form. Current clients should contact their attorney directly.

  • This field is for validation purposes and should be left unchanged.

Please be advised that any response to this email does not create an attorney-client relationship and, therefore, no attorney-client privilege is attached by this communication. You should not send any confidential information to the firm until you have received a written agreement from the firm to perform legal services on your behalf. Unless you have received such a written agreement, we will not consider any correspondence you send us as confidential. Do you agree with these terms?
ACCEPT the terms or Cancel the email.

Call Now Button