Kerr v. Commissioner
United States Tax Court
In 1993, Ps and their children formed two family limited partnerships (KFLP and KILP). The KFLP and KILP partnership agreements contain identical restrictions on liquidation of the partnerships.
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In 1993, Ps and their children formed two family limited partnerships (KFLP and KILP). The KFLP and KILP partnership agreements contain identical restrictions on liquidation of the partnerships. In June 1994, Ps transferred limited partnership interests in KFLP and KILP to the University of Texas (the university). On Dec. 28, 1994, Ps created separate grantor retained annuity trusts (GRAT's). Ps each transferred a 44.535-percent class B limited partnership interest in KFLP to their GRAT's. The GRAT's remainder interests were intended to benefit Ps grandchildren through generation-skipping…
1Opinion of the Court
OPINION
Jacobs, Judge:
This matter is before the Court on petitioners’ motion for partial summary judgment, filed pursuant to Rule 121.1 Petitioners contend that they are entitled to partial summary judgment that section 2704(b) is not applicable in valuing the limited partnership interests that they transferred to their grantor retained annuity trusts and to their children during 1994 and 1995.2 For the reasons set forth below, we will grant petitioners’ motion.
Background 3
Baine P. Kerr and Mildred C. Kerr were married in 1942 and have four adult children, Baine P. Kerr, Jr., John Caldwell…
2Cases cited17 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. TowerSupreme Court of the United States · 1946
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- United States v. BessSupreme Court of the United States · 1958
12 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Estate of Strangi v. CommissionerUnited States Tax Court · 2000
- Knight v. CommissionerUnited States Tax Court · 2000
- McCord v. Comm'rUnited States Tax Court · 2003
- Estate of Jones v. CommissionerUnited States Tax Court · 2001
- ESTATE OF ELMA MIDDLETON DAILEY v. COMMISSIONERUnited States Tax Court · 2001
17 more not listed; retrieve them via the Exa API.