Dowling ex rel. Estate of Dowling v. South Carolina Tax Commission

Toal, Justice:

The South Carolina Tax Commission appeals the circuit court’s valuation and characterization of certain transfers from the taxpayer (“Dowlings”)1 to their children. We affirm.

FACTS

In 1986 and 1987, Mr. Joab Dowling, Sr., and his wife, Katherine Dowling (“Dowlings”), transferred two thousand shares of Sherwood, Inc. to their five children. The 1986 transfers were characterized as part gift and part satisfaction of a prior debt owed the children by the Dowlings. The 1987 transfer was a gift to the children of the remaining shares in Sherwood, Inc.

Sherwood, Inc. is a corporation…