Charles T. McCord, Jr. and Mary S. McCord, Donors v. Commissioner

120 T.C. No. 13

UNITED STATES TAX COURT CHARLES T. MCCORD, JR., AND MARY S. MCCORD, DONORS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7048-00. Filed May 14, 2003. Ps, their children, and their children’s partnership formed a family limited partnership (PT). In 1996, Ps assigned interests in PT to several assignees pursuant to an agreement that contains a formula clause. The formula clause provides that (1) Ps’ children, trusts for their benefit, and S, a charitable organization, are to receive interests having an aggregate fair market value of a set dollar amount,…