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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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