Minahan v. Commissioner
United States Tax Court
Petitioners executed similar stock purchase agreements with separate trusts, each established for the primary benefit of an offspring of a petitioner. Pursuant to these agreements, petitioners sold unregistered common stock of a publicly traded corporation to each trust at a value equal to the stock exchange value as of the date of agreement. Each trust rendered an interest-bearing promissory note as partial payment.
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Petitioners executed similar stock purchase agreements with separate trusts, each established for the primary benefit of an offspring of a petitioner. Pursuant to these agreements, petitioners sold unregistered common stock of a publicly traded corporation to each trust at a value equal to the stock exchange value as of the date of agreement. Each trust rendered an interest-bearing promissory note as partial payment. Respondent began an audit to determine whether the agreements reflected fair market value. Petitioners refused to extend the statute of limitations on assessment. Respondent…
1Opinion of the Court
OPINION
CHABOT, Judge:
Respondent determined deficiencies in Federal gift tax against petitioners for the calendar quarter ended September 30, 1981, in the following amounts:
Docket No. Petitioner Deficiency
3146-85 Victor I. Minahan $882,737.74
3147-85-Marilee Minahan 882,737.93
3148-85 Estate of Mary M. Walter, deceased, the Marine Trust Co., N.A., personal representative 1,796,800.32
3203-85 Estate of John B. Torinus, deceased, the Kellogg Citizens National Bank and Louise B. Torinus, co-personal representatives 592,747.86
3204-85 Roger C. Minahan 549,888.83
3205-85 Louise B. Torinus 589,725.25
The…
2Cases cited25 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
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3Cited by148 opinions
- Sher v. CommissionerUnited States Tax Court · 1987
- Estate of Hall v. CommissionerUnited States Tax Court · 1989
- Gantner v. CommissionerUnited States Tax Court · 1989
- Estate of Jung v. CommissionerUnited States Tax Court · 1993
- MAGGIE MGMT. CO. v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 1997
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