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Lessons Learned<br />
The FLP/LLC must be able to show “substantial<br />
business and other non‐tax reasons” for formation:<br />
FLP/LLC assets should be monitored and actively<br />
managed;<br />
Management should be consistent with the<br />
purposes set forth when the FLP/LLC was set up;<br />
All required dtax returns should ldbe filed<br />
It is better that the FLP/LLC manage operating<br />
business assets than passive assets<br />
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