Think Outside the Tax Box
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Think Outside the Tax Box
What To Watch Out For With Family Limited Partnerships - 10-01-26
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The story of Anne Milner Fields is one of the reasons family limited partnership (FLP) opinions appeal to me so much. Born in 1925, she grew up in a small town in Texas and then moved to Dallas where she got a job as a secretary and met prominent oil man Bert Fields Sr. They married, and she lived the life of a socialite until he died in 1963. She consciously turned herself into a businesswoman, going so far as to take accounting courses.
Judge Copeland seems to have become a fan of hers:
“Ms. Fields's approach ultimately served her well: Her schooling, charisma, drive, and curiosity yielded good business decisions, which over time compounded into considerable personal wealth. She did not remarry or have children after Mr. Fields's passing.”
Having no children or grandchildren, she took her grandnephew, Bryan Milner, under her wing, paying for his education and mentoring him. In 2010, the year she turned 85, she made him executor of her estate and gave him a general power of attorney. He was also set to inherit the residue of her estate after some specific bequests. I really think we have the elements of a novel or a TV miniseries here, but we are tax people, so we are going to focus on how Anne’s estate tax was handled after she passed. It didn’t go well...
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