Estate of Jones v. Commissioner
United States Tax Court
D formed a family limited partnership (JBLP) with his son and transferred assets including real property, to JBLP in exchange for a 95.5389-percent limited partnership interest. D also formed a family limited partnership (AVLP) with his four daughters and transferred real property to AVLP in exchange for an 88.178-percent limited partnership interest.
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D formed a family limited partnership (JBLP) with his son and transferred assets including real property, to JBLP in exchange for a 95.5389-percent limited partnership interest. D also formed a family limited partnership (AVLP) with his four daughters and transferred real property to AVLP in exchange for an 88.178-percent limited partnership interest. D's son contributed real property in exchange for general and limited partnership interests in JBLP, and the daughters contributed real property in exchange for general and limited partnership interests in AVLP. All of the contributions were…
1Opinion of the Court
Cohen, Judge:
Respondent determined a deficiency of $4,412,527 in the 1995 Federal gift tax of W.W. Jones II. The issues for decision are (alternatively): (1) Whether the transfers of assets on formation of Jones Borregos Limited Partnership (jblp) and Alta Vista Limited Partnership (AVLP) (collectively, “the partnerships”) were taxable gifts pursuant to section 2512(b); (2) whether the period of limitations for assessment of gift tax deficiency arising from gifts on formation is closed; (3) whether restrictions on liquidation of the partnerships should be disregarded for gift tax valuation…
2Cases cited13 opinions
- United States v. CartwrightSupreme Court of the United States · 1973
- General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- Estate of Hall v. CommissionerUnited States Tax Court · 1989
8 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Linton v. United StatesDistrict Court, W.D. Washington · 2009
- Temple v. United StatesDistrict Court, E.D. Texas · 2006
- Estate of Bongard v. Comm'rUnited States Tax Court · 2005
- Estate of Bongard v. Comm'rUnited States Tax Court · 2005
- Estate of Foster v. Comm'rUnited States Tax Court · 2011
9 more not listed; retrieve them via the Exa API.