Estate of Samuel P. Black, Jr., Samuel P. Black, III v. Commissioner

133 T.C. No. 15

UNITED STATES TAX COURT ESTATE OF SAMUEL P. BLACK, JR., DECEASED, SAMUEL P. BLACK, III, EXECUTOR, ET AL.,1 Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 23188-05, 23191-05, Filed December 14, 2009. 23516-06. From 1927 until 1993, Mr. B was an employee, officer, or director of E (an insurance company) and was a major contributor to E’s success. In 1993, he, his son, P, and trusts for P’s two sons contributed their unencumbered E stock to BLP, a family limited partnership, in exchange for partnership interests proportionate to the fair market value of the…