Estate of Powell v. Comm'r
United States Tax Court
On August 8, 2008, D's son, J, acting on her behalf, transferred cash and securities to LP, a limited partnership, in exchange for a 99% limited partner interest. LP's partnership agreement allowed for the entity's dissolution with the written consent of all partners.
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On August 8, 2008, D's son, J, acting on her behalf, transferred cash and securities to LP, a limited partnership, in exchange for a 99% limited partner interest. LP's partnership agreement allowed for the entity's dissolution with the written consent of all partners. Also on August 8, 2008, J, purportedly acting under a power of attorney, transferred D's LP interest to T, a charitable lead annuity trust, the terms of which provided an annuity to a charitable organization for the rest of D's life. Upon D's death, T's corpus was to be divided equally between D's two sons. D died on August 15,…
1Opinion of the Court
ESTATE OF NANCY H. POWELL, DECEASED, JEFFREY J. POWELL, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Powell v. Comm'r
Docket Nos. 24703-12, 24731-12.1
United States Tax Court
2017 U.S. Tax Ct. LEXIS 19; 148 T.C. No. 18;
May 18, 2017, Filed
An appropriate order will be issued, and decisions will be entered for petitioner in docket No. 24703-12 and under Rule 155 in docket No. 24731-12.
On August 8, 2008, D's son, J, acting on her behalf, transferred cash and securities to LP, a limited partnership, in exchange for a 99% limited partner interest. LP's partnership…
Also in this document: Concurrence.
2Cases cited26 opinions
- Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Pennsylvania Coal Association, an Unincorporated Association v. Bruce Babbitt, Secretary of the Interior of the United States Department of Interior Robert Uram, Director, Office of Surface Mining Reclamation and Enforcement, United States Department of Interior, Pennsylvania Department of Environmental Resources (Der), Intervenor in D.C. Pennsylvania Coal Association, an Unincorporated Association v. Bruce Babbitt, Secretary of the Interior of the United States Department of Interior Robert Uram, Director, Office of Surface Mining Reclamation and Enforcement, United States Department of Interior Pennsylvania Department of Environmental Resources (Der), Intervenor in D.C. Commonwealth of Pennsylvania, Department of Environmental ResourcesCourt of Appeals for the Third Circuit · 1995
- United States v. ByrumSupreme Court of the United States · 1972
- Estate of Bongard v. Comm'rUnited States Tax Court · 2005
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