Estate of Wayne C. Bongard, James A. Bernards, Personal Representative v. Commissioner

124 T.C. No. 8

UNITED STATES TAX COURT ESTATE OF WAYNE C. BONGARD, DECEASED, JAMES A. BERNARDS, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6141-03. Filed March 15, 2005. In 1980, D incorporated Empak, Inc. In 1986, D established an irrevocable stock accumulation trust (ISA Trust) and funded it with some of his Empak stock. In the mid-1990s it was determined by Empak’s board of directors and advisers that pooling all of D’s family’s Empak stock in a holding company, WCB Holdings, LLC. (WCB Holdings), would better position Empak for a corporate…