Estate of Black v. Comm'r
United States Tax Court
From 1927 until 1993, Mr. B was an employee, officer, or director of E (an insurance company) and was a major contributor to E's success. In 1993, he, his son, P, and trusts for P's two sons contributed their unencumbered E stock to BLP, a family limited partnership, in exchange for partnership interests proportionate to the fair market value of the E stock each contributed.
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From 1927 until 1993, Mr. B was an employee, officer, or director of E (an insurance company) and was a major contributor to E's success. In 1993, he, his son, P, and trusts for P's two sons contributed their unencumbered E stock to BLP, a family limited partnership, in exchange for partnership interests proportionate to the fair market value of the E stock each contributed. Mr. B's advisers had explained the estate tax advantages of placing his E stock in BLP, but the transaction was initiated to implement Mr. B's buy-and-hold philosophy with respect to the family's E stock. Specifically,…
1Opinion of the Court
ESTATE OF SAMUEL P. BLACK, JR., DECEASED, SAMUEL P. BLACK, III, EXECUTOR, ET AL. 1, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Black v. Comm'r
Nos. 23188-05, 23191-05, 23516-06
United States Tax Court
133 T.C. 340; 2009 U.S. Tax Ct. LEXIS 35; 133 T.C. No. 15;
December 14, 2009, Filed
From 1927 until 1993, Mr. B was an employee, officer, or director of E (an insurance company) and was a major contributor to E's success. In 1993, he, his son, P, and trusts for P's two sons contributed their unencumbered E stock to BLP, a family limited partnership, in exchange for…
2Cases cited13 opinions
- United States v. Estate of GraceSupreme Court of the United States · 1969
- Estate of Bongard v. Comm'rUnited States Tax Court · 2005
- Jane C. Guynn, of the Estate of Vena E. Calvert, Deceased v. United StatesCourt of Appeals for the Fourth Circuit · 1971
- Estate of Bahr v. CommissionerUnited States Tax Court · 1977
- Todd v. CommissionerUnited States Tax Court · 1971
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