Dynamo Holdings Limited Partnership, Dynamo, GP, Inc., Tax Matters Partner v. Commissioner

150 T.C. No. 10

UNITED STATES TAX COURT DYNAMO HOLDINGS LIMITED PARTNERSHIP, DYNAMO, GP, INC., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent BEEKMAN VISTA, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 2685-11, 8393-12. Filed May 7, 2018. In these consolidated cases C, a corporation, and P, a partnership, share common ownership. During the years in issue C transferred property to P. R argues that the transfers were gifts among the ultimate beneficial owners. R argues in the alternative that the transfers were for less than fair…