Legal Opinion

Holman v. Comm'r

United States Tax Court

Decided May 27, 2008No. 7581-04Published

Ps transferred D stock of substantial value to a newly formed family limited partnership and then made gifts of limited partnership units (LP units) to a custodian for one of their children and in trust for the benefit of all of their children. Ps made a large gift in 1999 and smaller gifts in 2000 and 2001. In valuing the gifts for Federal gift tax purposes, they applied substantial discounts for minority interest status and lack of marketability.

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Ps transferred D stock of substantial value to a newly formed family limited partnership and then made gifts of limited partnership units (LP units) to a custodian for one of their children and in trust for the benefit of all of their children. Ps made a large gift in 1999 and smaller gifts in 2000 and 2001. In valuing the gifts for Federal gift tax purposes, they applied substantial discounts for minority interest status and lack of marketability. With respect to the 1999 gift, R argues that the gift should be treated as an indirect gift of D shares and not as a direct gift of LP units. For…

1Opinion of the Court

THOMAS H. HOLMAN, JR. AND KIM D.L. HOLMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Holman v. Comm'r

No. 7581-04

United States Tax Court

130 T.C. 170; 2008 U.S. Tax Ct. LEXIS 12; 130 T.C. No. 12;

May 27, 2008, Filed

Ps transferred D stock of substantial value to a newly formed family limited partnership and then made gifts of limited partnership units (LP units) to a custodian for one of their children and in trust for the benefit of all of their children. Ps made a large gift in 1999 and smaller gifts in 2000 and 2001. In valuing the gifts for Federal gift tax purposes, they…

2Cases cited20 opinions

  1. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  2. Higgins v. CommissionerSupreme Court of the United States · 1941
  3. Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
  4. Casey v. CommissionerUnited States Tax Court · 1962
  5. Estate of Reynolds v. CommissionerUnited States Tax Court · 1970

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