Walton v. Commissioner
United States Tax Court
P established and funded with corporate stock two substantially identical grantor retained annuity trusts (GRAT's). Each GRAT had a 2-year term during which P retained the right to receive an annuity. In the event that P died prior to expiration of the 2-year term, the remaining scheduled annuity payments were to be made to her estate. The balance of the trust property would then be paid to the remainder beneficiaries.
Read the full summary
P established and funded with corporate stock two substantially identical grantor retained annuity trusts (GRAT's). Each GRAT had a 2-year term during which P retained the right to receive an annuity. In the event that P died prior to expiration of the 2-year term, the remaining scheduled annuity payments were to be made to her estate. The balance of the trust property would then be paid to the remainder beneficiaries. HELD: For purposes of determining the value under sec. 2702, I.R.C., of the gift effected upon creation of each GRAT, P's retained qualified interest is to be valued as an…
1Opinion of the Court
OPINION
NlMS, Judge:
Respondent determined a deficiency in Federal gift tax against petitioner for 1993 in the amount of $4,532,776.82. The sole issue for decision is the valuation under section 2702 of gifts resulting from petitioner’s creation of two grantor retained annuity trusts (GRAT’s).
Unless otherwise indicated, all section' references are to sections of the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Background
This case was submitted fully stipulated pursuant to Rule 122, and the facts are so found.…
2Cases cited6 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States v. CorrellSupreme Court of the United States · 1967
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Central Pa. Sav. Ass'n v. CommissionerUnited States Tax Court · 1995
1 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Swallows Holding, Ltd. v. Comm'rUnited States Tax Court · 2006
- William A. Cook and Gayle T. Cook v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 2001
- Patricia A. Schott, Stephen C. Schott v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2003
- Audrey J. Walton v. CommissionerUnited States Tax Court · 2000
- Cook, William A. v. CIRCourt of Appeals for the Seventh Circuit · 2001
4 more not listed; retrieve them via the Exa API.