Cavallaro v. Commissioner
Court of Appeals for the First Circuit
1Opinion of the Court
HOWARD, Chief Judge.
William Cavallaro and his wife Patricia Cavallaro (together, “the Cavallaros”) appeal from a Tax Court decision affirming a determination by the Internal Revenue Service (“IRS”) Commissioner that they owed gift taxes on a $29,670,000 gift to their sons. After careful consideration, we affirm in part, reverse in part, and- remand to the Tax Court for further proceedings consistent with this opinion. .
I. BACKGROUND
In 1979, the Cavallaros started Knight Tool Co. (“Knight”), a contract manufacturing company that made custom tools and machine parts. William Cavallaro— whose…
2Cases cited29 opinions
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