Krabbenhoft v. Commissioner
United States Tax Court
Ps sold land to their sons on June 29, 1981, pursuant to an installment sale agreement, with interest on the remaining balance to be paid at the interest rate set by sec. 1.483-1(d)(1)(ii)(B), Income Tax Regs. R used a higher market interest rate to discount the installment payments in determining the value of the gift on the sale. Held, R used the proper interest rate to discount the installment payments as sec. 483 does not apply to gift tax valuation.
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Ps sold land to their sons on June 29, 1981, pursuant to an installment sale agreement, with interest on the remaining balance to be paid at the interest rate set by sec. 1.483-1(d)(1)(ii)(B), Income Tax Regs. R used a higher market interest rate to discount the installment payments in determining the value of the gift on the sale. Held, R used the proper interest rate to discount the installment payments as sec. 483 does not apply to gift tax valuation. Ballard v. Commissioner, 854 F.2d 185 (7th Cir. 1988), revg. T.C. Memo. 1987-128, not followed on this issue.
1Opinion of the Court
Lester H. Krabbenhoft and Anna Krabbenhoft, Petitioners v. Commissioner of Internal Revenue, Respondent
Krabbenhoft v. Commissioner
Docket No. 26561-87
United States Tax Court
94 T.C. 887; 1990 U.S. Tax Ct. LEXIS 61; 94 T.C. No. 56;
June 19, 1990, Filed
Decision will be entered under Rule 155.
Ps sold land to their sons on June 29, 1981, pursuant to an installment sale agreement, with interest on the remaining balance to be paid at the interest rate set by sec. 1.483-1(d)(1)(ii)(B), Income Tax Regs. R used a higher market interest rate to discount the installment payments in determining the value of…
2Cases cited6 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Eleanor M. Ballard v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
- Blackburn v. CommissionerUnited States Tax Court · 1953
- Cohen v. CommissionerUnited States Tax Court · 1989
- Ballard v. CommissionerUnited States Tax Court · 1987
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