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D has three assets which make up the vast majority of Ds estate: (i) Ds house (real estate) valued at $18,000,000, with an adjusted basis of $1,000,000, (ii) an operating business valued at $72,000,000, and (iii) a bank account with $10,000,000 cash. D has already used the majority of Ds unified credit. D would like to transfer these assets to the next generation at as low of a transfer tax cost as possible. D trusts the next generation (his four children) and is not opposed to ceding financial control to them, however, as D has superior working knowledge of the business, D would like to maintain some form of operational control at least until Ds children are ready to take over the business, and of course D needs a place to live. D has been told by one of Ds financial advisors that if he transfers some or all of his assets to a Partnership and then transfers/gifts non-voting (limited) partnership interests to Ds children, D will receive a transfer tax discount for lack of marketability (difficult to sell) and lack of control (if recipient cant vote their shares or is in a minority position). D has also been told that there is a possibility of reducing transfer taxes by transferring just a remainder interest to a trust a retaining an income interest for life.

Questions: 1. Is there support/authority for Ds advisors suggestion that D can receive a transfer tax discount (for marketability and control) if D transfers (gifts) limited partnership interests (non-voting) to his children? (YES or NO and citation).

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