Keller v. U.S., Civil Action No. V-02-62
Another taxpayer victory in Keller v. United States of America. At trial, the federal district court agreed that the funding of the FLP could be assumed to have taken place, even though the decedent had died before the assets were transferred. A wealthy Texas widow established
a family limited partnership (FLP) to be funded with $250 million in corporate investment bonds. In addition the federal district court approved the use of a combined 47.5% discount for lack of control and lack of marketability in the determination of the fair market value of two 49.95% limited partnership interests in the FLP.