Holman v. Commissioner: A Death Knell for the Tax Value of Transfer Restrictions in Family Limited Partnerships?

This Article examines a recent United States court of appeals case concerning section 2703, Holman v. Commissioner,7 and some earlier cases, including a few under the 1958 regulation, that are relevant to Holman. The purpose of this Article is to explain the current state of the law with respect to buy-sell type agreements and their influence on setting the transfer tax value. The Article begins with a discussion of the relevant Code and Regulations, focusing on section 2703 and its legislative history. The Article then follows with a look at some of the relevant case law and an in-depth look at Holman and ends with an analysis of the Holman decision.