Hackl v. Comm'r
United States Tax Court
In 1995 and 1996, Ps A and C made gifts to their children and grandchildren of membership units in Treeco, LLC, a limited liability company. Treeco had previously been organized by A to hold and operate tree farming properties. This timberland had been purchased by A to provide investment diversification in the form of long-term growth and future income.
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In 1995 and 1996, Ps A and C made gifts to their children and grandchildren of membership units in Treeco, LLC, a limited liability company. Treeco had previously been organized by A to hold and operate tree farming properties. This timberland had been purchased by A to provide investment diversification in the form of long-term growth and future income. Treeco was governed by an Operating Agreement which set forth the rights and duties conferred on members and the manager and which designated A as manager. At the time of the gifts, it was correctly anticipated that Treeco and its successor…
1Opinion of the Court
OPINION
NlMS, Judge:
By separate statutory notices, respondent determined a deficiency in the 1996 Federal gift tax liability of petitioner Christine M. Hackl (Christine Hackl) in the amount of $309,866 and in the 1996 Federal gift tax liability of petitioner Albert J. Hackl, Sr. (A.J. Hackl), in the amount of $309,950. Petitioners each timely filed for redetermination by this Court, and, due to an identity of issues, the cases were consolidated for purposes of trial, briefing, and opinion. In accordance with stipulations of partial settlement filed by the parties, the sole matter remaining for…
2Cases cited25 opinions
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- United States v. PelzerSupreme Court of the United States · 1941
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Helvering v. HutchingsSupreme Court of the United States · 1941
20 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Albert J. Hackl, Sr. And Christine M. Hackl v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2003
- Buckardt v. Comm'rUnited States Tax Court · 2010
- Christine M. Hackl v. CommissionerUnited States Tax Court · 2002
- Hackl v. Comm'rUnited States Tax Court · 2002
- Hackl, Albert J. v. CIRCourt of Appeals for the Seventh Circuit · 2003
1 more not listed; retrieve them via the Exa API.