J.C. Shepherd v. Commissioner

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115 T.C. No. 30

UNITED STATES TAX COURT J. C. SHEPHERD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2574-97. Filed October 26, 2000. P transferred to a newly formed family partner- ship, of which P is 50-percent owner and his two sons are each 25-percent owners, (1) P’s fee interest in timberland subject to a long-term timber lease and (2) stocks in three banks. Held: P’s transfers represent separate indirect gifts to his sons of 25 percent undivided interests in the leased timberland and stocks. Held, further, the fair market value of petitioner’s gifts determined.…