Harwood v. Commissioner
United States Tax Court
On Jan. 1, 1973, A, mother of B, C, and D, transferred to B and C her interest in the family partnership, in exchange for a note. On that same date, the partnership interests of B, C, and D were adjusted to give D an additional one-eighteenth interest and to reduce B and C's interests correspondingly. On Dec. 29, 1976, B and C formed trusts for the benefit of their children and transferred thereto 8.89-percent limited partnership interests in the family partnership.
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On Jan. 1, 1973, A, mother of B, C, and D, transferred to B and C her interest in the family partnership, in exchange for a note. On that same date, the partnership interests of B, C, and D were adjusted to give D an additional one-eighteenth interest and to reduce B and C's interests correspondingly. On Dec. 29, 1976, B and C formed trusts for the benefit of their children and transferred thereto 8.89-percent limited partnership interests in the family partnership. The family partnership agreement contained a restrictive clause entitling the partnership to buy out withdrawing partners at…
1Opinion of the Court
Forrester, Judge:
Respondent determined deficiencies in gift taxes for the petitioners in these cases as follows:
Docket No. Petitioner For calendar quarters ended: Deficiency
6557-81 Virginia Z. Harwood 3/31/73 12/31/76 $40,787 209,786
6558-81 Belva Y. Harwood 3/31/73 580,640
6559-81 Morris J. Harwood 3/31/73 12/31/76 12/31/78 12/31/79 91,888 221,848 12,420 16,210
6560-81 Margaret P. Harwood 12/31/76 189,558
6561-81 Arthur H. Harwood 3/31/73 12/31/76 40,787 209,786
After concessions, the issues for our decision are:(1) Whether Belva Harwood made a gift in 1973 to her sons, Arthur H. and Morris J.…
2Cases cited23 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Lord v. VeazieSupreme Court of the United States · 1850
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
18 more not listed; retrieve them via the Exa API.
3Cited by70 opinions
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- Ward v. CommissionerUnited States Tax Court · 1986
- Frazee v. CommissionerUnited States Tax Court · 1992
- Snyder v. CommissionerUnited States Tax Court · 1989
- CTUW Hollingsworth v. CommissionerUnited States Tax Court · 1986
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