Legal Opinion

Hackl v. Comm'r

United States Tax Court

Decided March 27, 2002No. 6921-00; No. 6922-00Published

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

CHRISTINE M. HACKL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent ALBERT J. HACKL, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hackl v. Comm'r

No. 6921-00; No. 6922-00

United States Tax Court

118 T.C. 279; 2002 U.S. Tax Ct. LEXIS 16; 118 T.C. No. 14;

March 27, 2002, Filed

Petitioners not entitled to exclusions under section 2503(b) for their gifts of Treeco units.

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…

2Cases cited25 opinions

  1. United States v. National Bank of CommerceSupreme Court of the United States · 1985
  2. United States v. PelzerSupreme Court of the United States · 1941
  3. Fondren v. CommissionerSupreme Court of the United States · 1945
  4. Commissioner v. DisstonSupreme Court of the United States · 1945
  5. Helvering v. HutchingsSupreme Court of the United States · 1941

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