Steinberg v. Commissioner
United States Tax Court
P entered into a binding gift agreement with her daughters under which P gave her daughters cash and securities and in exchange the daughters agreed to assume and to pay, among other things, any estate tax liability imposed under I.R.C. sec. 2035(b) as a result of the gifts in the event that P passed away within three years of the gifts.
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P entered into a binding gift agreement with her daughters under which P gave her daughters cash and securities and in exchange the daughters agreed to assume and to pay, among other things, any estate tax liability imposed under I.R.C. sec. 2035(b) as a result of the gifts in the event that P passed away within three years of the gifts. In calculating for gift tax purposes the gross fair market value of the property transferred to the daughters, P reduced the fair market value of the cash and securities by an amount representing the value of the daughters' assumption of the potential I.R.C.…
1Opinion of the Court
JEAN STEINBERG, DONOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Steinberg v. Comm'r
Docket No. 23865-11.
United States Tax Court
141 T.C. 258; 2013 U.S. Tax Ct. LEXIS 39; 141 T.C. No. 8;
September 30, 2013, Filed
An appropriate order will be issued.
P entered into a binding gift agreement with her daughters under which P gave her daughters cash and securities and in exchange the daughters agreed to assume and to pay, among other things, any estate tax liability imposed under I.R.C. sec. 2035(b) as a result of the gifts in the event that P passed away within three years of the gifts.
Also in this document: Concurrence · Goeke; Concurrence · Lauber; Dissent.
2Cases cited36 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Bull v. United StatesSupreme Court of the United States · 1935
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
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