CTUW Hollingsworth v. Commissioner
United States Tax Court
Decedent transferred property in 1967 to a closely held corporation for a $ 480,000 note. Held, fair market value of the property was $ 726,122 on the date of transfer, and a gift was made to the extent the fair market value of the property exceeded the face amount of the note.
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Decedent transferred property in 1967 to a closely held corporation for a $ 480,000 note. Held, fair market value of the property was $ 726,122 on the date of transfer, and a gift was made to the extent the fair market value of the property exceeded the face amount of the note. Held, further, because the $ 30,000 lifetime exemption from taxable gifts was utilized by the decedent with respect to gifts made in 1972, no exemption is now available with respect to the gift made in 1967. Held, further: The gift does not qualify for the $ 3,000 per donee annual exclusion from taxable gifts because a…
1Opinion of the Court
SWIFT, Judge:
In separate notices of deficiency dated January 22, 1981, respondent determined a deficiency for 1967 in the Federal gift tax liability of Mrs. Georgia L. Ketteman (Mrs. Ketteman), deceased, in the amount of $458,126.25, and an addition to tax under section 6651(a)(1)1 in the amount of $114,531.56. By amendment to his answer, respondent reduced the amount of Mrs. Ketteman’s Federal gift tax deficiency to $149,743.75 and the amount of the addition to tax to $37,435.94.
Mrs. Ketteman died on December 24, 1972, and petitioners herein were the beneficiaries of her estate. Respondent,…
2Cases cited24 opinions
- United States v. CartwrightSupreme Court of the United States · 1973
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Messing v. CommissionerUnited States Tax Court · 1967
19 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- Stanley Works v. CommissionerUnited States Tax Court · 1986
- Estate of Spruill v. CommissionerUnited States Tax Court · 1987
- Shepherd v. CommissionerUnited States Tax Court · 2000
- Estate of La Meres v. Comm'rUnited States Tax Court · 1992
- 885 Inv. Co. v. CommissionerUnited States Tax Court · 1990
33 more not listed; retrieve them via the Exa API.