The elements of family intimacy and tax reduction, which present themselves conveniently in the common law concepts of gifts, assignments, and trusts, have proven to be danger signs which herald the scrutiny of the Bureau of Internal Revenue and forecast probable tax disaster for the taxpayer. Normally and unavoidably, family partnerships have come to be categorized with these concepts, and the Bureau, in its efforts to protect the revenue, would, with the assistance of the Tax Court, thwart the effectiveness of these business units in a manner similar to the treatment accorded to the aforementioned concepts.
Martin, T. Baldwin Jr.
"The Tax Consequences of Family Parnerships,"
Mercer Law Review: Vol. 1:
2, Article 4.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol1/iss2/4