Legal Opinion
Estate of Theodore Thompson, Deceased, Betsy T. Turner v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided September 1, 2004No. 03-3173PublishedCited by 32 opinions
1Opinion of the Court
SCIRICA, Chief Judge.
This case involves the application of § 2036(a) of the Internal Revenue Code, 26 U.S.C. § 2036(a), to assets transferred inter vivos to family limited partnerships. Theodore R. Thompson transferred $2.8 million in securities and other assets to two family limited partnerships in exchange for pro-rata partnership interests. Upon his death, Thompson’s estate filed a federal estate tax return which applied a forty percent discount to the value of decedent’s partnership interests for lack of control and marketability. The Commissioner of Internal Revenue filed a notice of…
2Cases cited14 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- United States v. Estate of GraceSupreme Court of the United States · 1969
- Estate of Daniel McNichol Deceased, Ellen McNichol Evangelista and Joseph G. McNichol Executors v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Wayne Bolt & Nut Co. v. CommissionerUnited States Tax Court · 1989
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3Cited by32 opinions
- Estate of Bongard v. Comm'rUnited States Tax Court · 2005
- Estate of Black v. Comm'rUnited States Tax Court · 2009
- In Re Estate of HjerstedSupreme Court of Kansas · 2008
- Holman v. CommissionerCourt of Appeals for the Eighth Circuit · 2010
- Estate of Bigelow v. Comm'rUnited States Tax Court · 2005
27 more not listed; retrieve them via the Exa API.