Wendy C. Gerzog (Baltimore) has published Hurford: Family Limited Partnership Practice Pointers, 122 Tax Notes 799 (Feb. 9, 2009). Here is the abstract:
Sometimes a case offers practice pointers: Hurford [v. Commissioner, T.C. Mem. 2008-278 (Dec. 11, 2008)] is one such case. Besides explaining what not to do (that is, what was actually done in the case), the Tax Court continually commented on what the decedent and her family might have done to improve their chances of success. The taxpayers in this case attempted to use family limited partnerships (FLPs) and a private annuity to reduce gift and estate taxes.
