Knight v. Commissioner
United States Tax Court
On Dec. 28, 1994, Ps established a trust of which P-H was trustee (the management trust), a family limited partnership (the partnership) of which the management trust was the general partner, and trusts for the benefit of each of Ps' two adult children (the children's trusts). Ps transferred three parcels of real property used by Ps and their children and some financial assets to the partnership.
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On Dec. 28, 1994, Ps established a trust of which P-H was trustee (the management trust), a family limited partnership (the partnership) of which the management trust was the general partner, and trusts for the benefit of each of Ps' two adult children (the children's trusts). Ps transferred three parcels of real property used by Ps and their children and some financial assets to the partnership. Each P transferred a 22.3- percent interest in the partnership to each of their children's trusts. The parties stipulated that the steps to create the partnership satisfied all requirements under…
1Opinion of the Court
Colvin, Judge:
In separate notices of deficiency sent to each petitioner, respondent determined that each petitioner has a gift tax deficiency of $120,866 for 1994.
Petitioners formed a family limited partnership called the Herbert D. Knight Limited Partnership (the partnership), and gave interests in it to trusts they established for their children. After concessions, the issues for decision are:(1) Whether, as respondent contends, the partnership is disregarded for Federal gift tax purposes. We hold that it is not.(2) Whether, as petitioners contend, the fair market value of petitioners’…
2Cases cited31 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
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- Aquilino v. United StatesSupreme Court of the United States · 1960
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- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
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