Estate of Turner v. Comm'r
United States Tax Court
P filed a motion for reconsideration of our Memorandum Opinion Estate of Turner v. Commissioner, T.C. Memo. 2011-209 (Estate of Turner I). In Estate of Turner I decedent (D) transferred property to a family limited partnership (FLP) in exchange for limited and general partnership interests. D transferred portions of the limited FLP interest as gifts during his lifetime.
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P filed a motion for reconsideration of our Memorandum Opinion Estate of Turner v. Commissioner, T.C. Memo. 2011-209 (Estate of Turner I). In Estate of Turner I decedent (D) transferred property to a family limited partnership (FLP) in exchange for limited and general partnership interests. D transferred portions of the limited FLP interest as gifts during his lifetime. In Estate of Turner I we held that the inter vivos transfer of property to the FLP was subject to I.R.C. sec. 2036. Among other arguments, the estate contends that under D's will, the surviving spouse's right to the pecuniary…
1Opinion of the Court
SUPPLEMENTAL OPINION
Marvel, Judge:
In a timely filed motion for reconsideration (motion) pursuant to Rule 161,1 the Estate of Clyde W. Turner, Sr. (Clyde Sr.), requests the Court to reconsider its Memorandum Opinion Estate of Turner v. Commissioner, T.C. Memo. 2011-209 (Estate of Turner I).
In Estate of Turner I we held, among other things, that Clyde Sr.’s inter vivos transfer of property to Turner & Co. was subject to section 2036 and that the values of those transferred assets are included in the value of his gross estate. The estate requests that we reconsider and/or supplement our findings…
2Cases cited6 opinions
- Knudsen v. Comm'rUnited States Tax Court · 2008
- Vaughn v. CommissionerUnited States Tax Court · 1986
- ESTATE OF QUICK v. COMMISSIONERUnited States Tax Court · 1998
- Estate of Black v. Comm'rUnited States Tax Court · 2009
- Estate of Letts v. CommissionerUnited States Tax Court · 1997
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