id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-421	Burke, Karen C.; McCouch, Grayson M.P.	Family Limited Partnerships: Discounts, Options, and Disappearing Value	2022	24	.pdf	application/pdf	11731	543	53	Although the distinction may seem highly formalistic, an indirect gift18 of assets at the time of the contribution is apparently taxed more heavily than a gift of partnership interests following a contribution. The carryover basis rule for gifts of partnership interests merely serves to mask the capital shift between A and D. By contrast, a sale of a discounted interest between unrelated parties results in an economic loss to the transferor and a matching potential economic gain to the transferee.	cache/ftr-421.pdf	txt/ftr-421.txt