Page 1 of 1

Family Limited Partnerships

Posted: Wed Mar 03, 2010 11:43 am
by Yahoo Bot

They value them whichever way is better for the creditors.
Dennis McGoldrick
350 S. Crenshaw Bl., #A207B
Torrance, CA 90503
On Mar 2, 2010, at 1:25 PM, "Gerry McNally" wrote:
Dear Listmates,
PC was gifted years ago with a 9% interest in a family limited partnership. Assuming the liquidation value of the partnership asset(s), less a (37% discount for lack of control, and marketability) is more than PC can exempt, how do the Ch7 trustees treat these FLP interests. Do they value them on liquidation value or on distributions.
Gerald McNally
McNally & Associates, P.C.
517 E. Wilson Ave. #104
Glendale, CA 91206
818-507-5100
They value them whichever way is better for the creditors.Dennis McGoldrick350 S. Crenshaw Bl., #A207BTorrance, CA 90503On Mar 2, 2010, at 1:25 PM, "Gerry McNally" <gm88008@mcesq.com> wrote:

Dear Listmates,

PC was gifted years ago with a 9% interest in a family
limited partnership. Assuming the liquidation value of the partnership
asset(s), less a (37% discount for lack of control, and marketability) is more
than PC can exempt, how do the Ch7 trustees treat these FLP interests. Do
they value them on liquidation value or on distributions.

Gerald McNally
McNally & Associates, P.C.
517 E. Wilson Ave. #104
Glendale, CA 91206
818-507-5100


The post was migrated from Yahoo.

Family Limited Partnerships

Posted: Tue Mar 02, 2010 4:04 pm
by Yahoo Bot

Ultimately it is about what money can the trustee obtain from the
interest. Valuation discount really does not matter if the trustee can
obtain funds above the exempt amount either through distributions or
sale. The higher the liquidation value, the more likely the trustee's
scrutiny. Is there a clause restricting sale rights by the limited
partners? A few other things to think about are first what is the
expiration date of the limited partnership? If soon, it has more value
than if later. Second, if there is a restriction on sale clause
limited sales to other limited partners or only with the general
partner's permission, would another of the limited partners or the
partnership itself want to purchase the pc interest for a relative (no
pun intended) song from the Chapter 7 trustee if value existed above
the exempt amount? Third, are there any financial irregularities in
the administration of the general partnership that support an action
for dissolution by the Chapter 7 trustee on behalf of the bk estate?
I recently was involved in a case where the debtor had an 8%
interest in FLP with strict sale restrictions that required approval
of the General Partner unless sold to another limited partner. Client
tried to sell, but since she was not on good terms with the General
Partner, the answer was no and none of the other family members wanted
to buy her interest. Chapter 7 was her last resort. Chapter 7 trustee
delved into the partnership records, took a Rule 2004 exam of the GP
and then filed an adversary proceeding seeking to dissolve the limited
partnership based on California law alleging improprieties by the GP.
The GP strongly refuted the allegations, but rather than spend money
to fight the adversary proceeding, the GP made the smart business
decision and agreed for the partnership to buy the debtor's 8%
interest for not more than 1/3 of what the debtor believed the
liquidation value. Thus the sale restriction clause was used as a
hammer to enrich the other limited partners at the debtor's expense,
while the Chapter 7 estate obtained a significant chunk it never would
have obtained if all members of the FLP wanted to protect the debtor.
Without the trustee's aggressive action in filing the Adversary, the
GP probably would never have thought of offering to buy the debtor's
interest at a huge discount.
Mark T. Jessee
Law Offices of Mark T. Jessee
"A Debt Relief Agency"
50 W. Hillcrest Drive, Suite 200
Thousand Oaks, CA 91360
(805) 497-5868
On Tue 2/03/10 2:20 PM , "Steven B. Lever" sblever@leverlaw.com
sent:
This is not a very marketable asset in most cases. Only if there is
a consistent cash cow in the partnership would the Trustee likely be
interested in it. If it is merely a holding vehicle for assets that
dont produce much cash it would be a better bet that trustee will
pass. Small minority owners often dont know what is in the LP, but
have the PC look into it. Also look into the partnership
documentation for both due diligence reasons and the trustee is likely
to ask for it. Many partnership agreements have provisions that
protect the partnership from having new partner interests forced on
them.
Valuation for gift purposes is done by appraisal. Valuation for
trustee purposes is for actual sale, which may or may not be
practicable.
Law Offices of Steven B. Lever
FROM: cdcbaa@yahoogroups.com [mailto:cdcbaa@yahoogroups.com] ON
BEHALF OF Gerry McNally
SENT: Tuesday, March 02, 2010 1:26 PM
TO: cdcbaa@yahoogroups.com
SUBJECT: [cdcbaa] Family Limited Partnerships
Dear Listmates,
PC was gifted years ago with a 9% interest in a family limited
partnership. Assuming the liquidation value of the partnership
asset(s), less a (37% discount for lack of control, and marketability)
is more than PC can exempt, how do the Ch7 trustees treat these FLP
interests. Do they value them on liquidation value or on
distributions.
Gerald McNally
McNally & Associates, P.C.
517 E. Wilson Ave. #104
Glendale, CA 91206
818-507-5100
Links:
[1] mailto:cdcbaa@yahoogroups.com?subjectRE: [cdcbaa] Family Limited
Partnerships
[2]

The post was migrated from Yahoo.

Family Limited Partnerships

Posted: Tue Mar 02, 2010 3:02 pm
by Yahoo Bot

charset="windows-1251"
See Section 363(h) as major risk.
David A. Tilem
Certified Bankruptcy Specialist*
Law Offices of David A. Tilem (a debt relief agency)
206 N. Jackson Street, #201, Glendale, CA 91206
Tel: 818-507-6000 Fax: 818-507-6800
* Bankruptcy specialist cert. by State Bar of CA Bd of Legal
Specialization.
Gerry McNally
Sent: Tuesday, March 02, 2010 1:26 PM
To: cdcbaa@yahoogroups.com
Subject: [cdcbaa] Family Limited Partnerships
Dear Listmates,
PC was gifted years ago with a 9% interest in a family limited partnership.
Assuming the liquidation value of the partnership asset(s), less a (37%
discount for lack of control, and marketability) is more than PC can exempt,
how do the Ch7 trustees treat these FLP interests. Do they value them on
liquidation value or on distributions.
Gerald McNally
McNally & Associates, P.C.
517 E. Wilson Ave. #104
Glendale, CA 91206
818-507-5100
charset="windows-1251"
Message
See Section 363(h) as major
risk.


David A.
Tilem
Certified Bankruptcy
Specialist*
The post was migrated from Yahoo.

Family Limited Partnerships

Posted: Tue Mar 02, 2010 2:20 pm
by Yahoo Bot

This is not a very marketable asset in most cases. Only if there is a
consistent cash cow in the partnership would the Trustee likely be
interested in it. If it is merely a holding vehicle for assets that
don't produce much cash it would be a better bet that trustee will pass.
Small minority owners often don't know what is in the LP, but have the
PC look into it. Also look into the partnership documentation for both
due diligence reasons and the trustee is likely to ask for it. Many
partnership agreements have provisions that protect the partnership from
having new partner interests forced on them.
Valuation for gift purposes is done by appraisal. Valuation for trustee
purposes is for actual sale, which may or may not be practicable.
Law Offices of Steven B. Lever

The post was migrated from Yahoo.

Family Limited Partnerships

Posted: Tue Mar 02, 2010 1:47 pm
by Yahoo Bot

Is 37% enough discount for a 9% holding of a family limited partnership?
Assuming the FLP has an actual business purpose I would think the discount
would be greater.
Larry Webb
email Larry@Webbklaw.com
Law Office of Larry Webb
484 Mobil Ave. Suite 43
Camarillo California 93010
805 987 1400
Fax 805 987 2866
WARNING And Tax disclaimer
This E-mail is covered by the Electronic Communications Privacy Act, 18
U.S.C. 2510-2521 and is legally privileged. This information is
confidential information and is intended only for the use of the individual
or entity named above. If the reader of this message is not the intended
recipient, you are hereby notified that any dissemination, distribution or
copying of this communication is strictly prohibited. It is for the use of
the named addressees and may not be disclosed to anyone else without the
express consent of the originator. If you have received it in error you must
not use, disclose,copy, or rely on its contents and should destroy it
immediately. If you need any further information, please contact the
originator of this message.
IRS Circular 230 Disclaimer: To ensure compliance with IRS Circular 230, any
U.S. federal tax advice provided in this communication is not intended or
written to be used, and it cannot be used by the recipient or any other
taxpayer (i) for the purpose of avoiding tax penalties that may be imposed
on the recipient or any other taxpayer, or (ii) in promoting, marketing or
recommending to another party a partnership or other entity, investment
plan, arrangement or other transaction addressed herein.

The post was migrated from Yahoo.

Family Limited Partnerships

Posted: Tue Mar 02, 2010 1:25 pm
by Yahoo Bot

Dear Listmates,
PC was gifted years ago with a 9% interest in a family limited
partnership. Assuming the liquidation value of the partnership
asset(s), less a (37% discount for lack of control, and marketability)
is more than PC can exempt, how do the Ch7 trustees treat these FLP
interests. Do they value them on liquidation value or on
distributions.
Gerald McNally
McNally & Associates, P.C.
517 E. Wilson Ave. #104
Glendale, CA 91206
818-507-5100
Dear Listmates,

PC was gifted years ago with a 9% interest in a family
limited partnership. Assuming the liquidation value of the partnership
asset(s), less a (37% discount for lack of control, and marketability) is more
than PC can exempt, how do the Ch7 trustees treat these FLP interests. Do
they value them on liquidation value or on distributions.

Gerald McNally
McNally & Associates, P.C.
517 E. Wilson Ave. #104
Glendale, CA 91206
818-507-5100


The post was migrated from Yahoo.