Legal Opinion
Estate of Petter v. Commissioner
Court of Appeals for the Ninth Circuit
Decided August 4, 2011No. 10-71854PublishedCited by 7 opinions
1Opinion of the Court
OPINION
BYBEE, Circuit Judge:
Anne Y. Petter (“Taxpayer” or “Anne”) transferred membership units in a family-owned LLC partly as a gift and partly by sale to two trusts and coupled the transfers with simultaneous gifts of LLC units to two charitable foundations. The transfer documents include both a dollar formula clause — which assigns to the trusts a number of LLC units worth a specified dollar amount and assigns the remainder of the units to the foundations — and a reallocation clause — which obligates the trusts to transfer additional units to the foundations if the value of the units the…
2Cases cited10 opinions
- United States v. Tohono O’odham NationSupreme Court of the United States · 2011
- Robert P. Wilcox v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Humes v. United StatesSupreme Court of the United States · 1928
- Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
- United Dominion Industries, Inc. v. United StatesSupreme Court of the United States · 2001
5 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- High Desert Relief, Inc. v. United StatesCourt of Appeals for the Tenth Circuit · 2019
- Graev v. CommissionerUnited States Tax Court · 2013
- Nelson v. CIRCourt of Appeals for the Fifth Circuit · 2021
- Estate of Howard v. Moore, Virgil L. Moore, and Trustee v. CommissionerUnited States Tax Court · 2020
- James C. Nelson v. CommissionerUnited States Tax Court · 2020
2 more not listed; retrieve them via the Exa API.