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Look, the fogeys have gifted the interests in the limited partnerships to children, not the assets. Therefore the limited partners do have no control inside the assets. Therefore the value of the interest is gloomier than the cost of the profits. So a discount must be permitted on value of the equipment. Many court decisions have upheld this or perhaps IRS says. For estate, the discount is big, while for liquid assets (like cash) the discount is of course small. Generally IRS allows 40% discount, based along the nature of assets. Continuing the above example, the location where assets transferred are $3 million, the loan exclusion can $1.8 m. This is $1.2 million more with the limited jv.
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