Peracchio v. Comm'r
United States Tax Court
P transferred limited partner interests in a family limited partnership (PT) to a family trust (T) pursuant to two separate transactions. In one of the transactions, P transferred a 45.47- percent limited partner interest to T for no consideration. In the other transaction, P transferred a 53.48-percent limited partner interest to T in exchange for T's promissory note in the amount of $ 646,764. Held: Fair market value of the transferred PT interests determined.
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P transferred limited partner interests in a family limited partnership (PT) to a family trust (T) pursuant to two separate transactions. In one of the transactions, P transferred a 45.47- percent limited partner interest to T for no consideration. In the other transaction, P transferred a 53.48-percent limited partner interest to T in exchange for T's promissory note in the amount of $ 646,764. Held: Fair market value of the transferred PT interests determined. See sec. 2512, I.R.C.
1Opinion of the Court
PETER S. PERACCHIO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Peracchio v. Comm'r
No. 10470-01
United States Tax Court
T.C. Memo 2003-280; 2003 Tax Ct. Memo LEXIS 279; 86 T.C.M. (CCH) 412;
September 25, 2003, Filed
Value of assets subject to gift tax determined.
P transferred limited partner interests in a family limited
partnership (PT) to a family trust (T) pursuant to two separate
transactions. In one of the transactions, P transferred a 45.47-
percent limited partner interest to T for no consideration. In
the other transaction, P transferred a 53.48-percent limited
partner interest…
2Cases cited11 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Parker v. CommissionerUnited States Tax Court · 1986
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
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