Estate of Sommers v. Comm'r
United States Tax Court
Both P and R have moved for partial summary judgment on the issue of whether D (1) made gifts to his nieces (intervenors herein), in 2001 and 2002, of all the units of an LLC holding works of art contributed to the LLC by D, as R and intervenors argue, or (2) retained and, within three years of his death, relinquished the power to "alter, amend, revoke, or terminate" those gifts, within the meaning of I.R.C. sec. 2038(a)(1), so that the LLC units are includable in D's gross…
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Both P and R have moved for partial summary judgment on the issue of whether D (1) made gifts to his nieces (intervenors herein), in 2001 and 2002, of all the units of an LLC holding works of art contributed to the LLC by D, as R and intervenors argue, or (2) retained and, within three years of his death, relinquished the power to "alter, amend, revoke, or terminate" those gifts, within the meaning of I.R.C. sec. 2038(a)(1), so that the LLC units are includable in D's gross estate pursuant to I.R.C. sec. 2035(a), as P argues (date-of-gift issue). D and the nieces had agreed that his gifts of…
1Opinion of the Court
ESTATE OF SHELDON C. SOMMERS, DECEASED, BERNICE LANG SOMMERS, EXECUTRIX, Petitioner, AND WENDY SOMMERS, JULIE SOMMERS NEUMAN, AND MARY LEE SOMMERS-GOSZ, Intervenors v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Sommers v. Comm'r
Docket Nos. 9305-07, 9306-07
United States Tax Court
T.C. Memo 2013-8; 2013 Tax Ct. Memo LEXIS 10; 105 T.C.M. (CCH) 1041;
January 10, 2013, Filed
In re Estate of Sommers, 2010 N.J. Super. Unpub. LEXIS 1122 (App.Div., May 25, 2010)
Both P and R have moved for partial summary judgment on the issue of whether D (1) made gifts to his nieces (intervenors herein), in…
2Cases cited25 opinions
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme Court of the United States · 1979
- Riggs v. Del DragoSupreme Court of the United States · 1942
- United States v. MitchellSupreme Court of the United States · 1971
- United States v. Itt Rayonier, IncorporatedCourt of Appeals for the Ninth Circuit · 1980
20 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Estate of Sommers v. Comm'rUnited States Tax Court · 2017