CTUW Hollingsworth v. Commissioner
United States Tax Court
Decedent transferred property in 1967 to a closely held corporation for a $ 480,000 note. Held, fair market value of the property was $ 726,122 on the date of transfer, and a gift was made to the extent the fair market value of the property exceeded the face amount of the note.
Read the full summary
Decedent transferred property in 1967 to a closely held corporation for a $ 480,000 note. Held, fair market value of the property was $ 726,122 on the date of transfer, and a gift was made to the extent the fair market value of the property exceeded the face amount of the note. Held, further, because the $ 30,000 lifetime exemption from taxable gifts was utilized by the decedent with respect to gifts made in 1972, no exemption is now available with respect to the gift made in 1967. Held, further: The gift does not qualify for the $ 3,000 per donee annual exclusion from taxable gifts because a…
1Opinion of the Court
CTUW Georgia Ketteman Hollingsworth, Georgia L. Ketteman Testamentary Trust FBO John M. and Jean B. Reineke, S. Preston Williams, Estate of John M. Reineke, Jean B. Reineke, William K. Hollingsworth, and Norma L. Hollingsworth, Petitioners v. Commissioner of Internal Revenue, Respondent
CTUW Hollingsworth v. Commissioner
Docket No. 7936-81
United States Tax Court
86 T.C. 91; 1986 U.S. Tax Ct. LEXIS 160; 86 T.C. No. 7;
January 28, 1986, Filed
Decision will be entered under Rule 155.
Decedent transferred property in 1967 to a closely held corporation for a $ 480,000 note. Held, fair market value of…
2Cases cited25 opinions
- United States v. CartwrightSupreme Court of the United States · 1973
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Messing v. CommissionerUnited States Tax Court · 1967
20 more not listed; retrieve them via the Exa API.