Albert J. Hackl, Sr. And Christine M. Hackl v. Commissioner of Internal Revenue

TERENCE T. EVANS, Circuit Judge.

Most post-retirement hobbies don’t involve multi-million dollar companies or land retirees in hot water with the IRS, but those are the circumstances in this case. Albert J. (A.J.) and Christine M. Hackl began a tree-farming business after A.J.’s retirement and gave shares in the company to family members. The Hackls believed the transfers were excludable from the gift tax, but the IRS thought otherwise. The Tax Court agreed with the IRS, Hackl v. Comm’r, 118 T.C. 279, 2002 WL 467117 (2002), resulting in a gift tax deficiency of roughly $400,000 for the couple.…