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Not AuthorityTax Court· Primary source linked· Unreviewed

Tax Court opinion in Estate of Whitford — §2036 FLP inclusion despite written purpose memo

Tax Court · Fetched 2026-04-30 09:00 UTC · sonar-pro

Scout Summary

In Estate of Whitford v. Commissioner, T.C. Memo. 2026-48, the Tax Court held that a contemporaneous non-tax-purpose memorandum was insufficient to overcome §2036(a) inclusion where the decedent retained day-to-day control of FLP investments after formation. Follows Powell and Cahill in extending the implied-agreement analysis.

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Practitioner Action

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Provenance

Item ID
news_18
Topic Key
tax_court_significant_opinions
Authority
news_reference
Scout Model
sonar-pro
Fetched At
2026-04-30T09:00:00.000Z
Reviewed At
—
Not Authority

Run primary-source research before citing.