Calder v. Commissioner
United States Tax Court
Upon the facts, held: 1. P's transfer to four trusts, involving six beneficiaries, constituted six separate gifts. 2. A blockage discount should be applied to each gift separately in valuing P's gifts, based on the actual annual sales figure for each of the gifts. 3. P's gifts did not create present interests which qualified for exclusion from the gift tax under sec. 2503(b), I.R.C. 1954.
1Opinion of the Court
Kórner, Judge:
Respondent determined a Federal gift tax deficiency against Louisa J. Calder (hereinafter petitioner) for the taxable quarter ending December 31, 1976, in the amount of $459,418.60.
The issues for decision are: (1) Whether petitioner’s transfers on December 21, 1976, to four trusts, involving six beneficiaries, constituted four or six separate gifts; (2) whether a blockage discount should be applied in valuing petitioner’s gifts and, if so, should it be applied to each gift, separately, or applied on an aggregate basis, and in what amounts; and (3) whether petitioner is entitled…
2Cases cited28 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- United States v. PelzerSupreme Court of the United States · 1941
- Merrill v. FahsSupreme Court of the United States · 1945
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
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3Cited by20 opinions
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- Conrad Janis Maria G. Janis v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- Froh v. CommissionerUnited States Tax Court · 1993
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