McCord v. Comm'r
United States Tax Court
Ps, their children, and their children's partnership formed a family limited partnership (PT). In 1996, Ps assigned interests in PT to several assignees pursuant to an agreement that contains a formula clause.
Read the full summary
Ps, their children, and their children's partnership formed a family limited partnership (PT). In 1996, Ps assigned interests in PT to several assignees pursuant to an agreement that contains a formula clause. The formula clause provides that (1) Ps' children, trusts for their benefit, and S, a charitable organization, are to receive interests having an aggregate fair market value of a set dollar amount, and (2) C, another charitable organization, is to receive any remaining portion of the assigned interests. Ps' children agreed to pay all transfer taxes resulting from the transaction,…
1Opinion of the Court
CHARLES T. MCCORD, JR., AND MARY S. MCCORD, DONORS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
McCord v. Comm'r
No. 7048-00
United States Tax Court
120 T.C. 358; 2003 U.S. Tax Ct. LEXIS 16; 120 T.C. No. 13;
May 14, 2003, Filed
VASQUEZ, J., agrees with this dissenting opinion.
Ps, their children, and their children's partnership formed
a family limited partnership (PT). In 1996, Ps assigned
interests in PT to several assignees pursuant to an agreement
that contains a formula clause. The formula clause provides that(1) Ps' children, trusts for their benefit, and S, a charitable
organizatio…
Also in this document: Concurrence; Concurring in part, dissenting in part · Chiechi; Concurring in part, dissenting in part · Foley; Dissent.
2Cases cited54 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- James v. United StatesSupreme Court of the United States · 1961
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- United States v. CartwrightSupreme Court of the United States · 1973
49 more not listed; retrieve them via the Exa API.