Estate of Black v. Comm'r
United States Tax Court
From 1927 until 1993, Mr. B was an employee, officer, or director of E (an insurance company) and was a major contributor to E's success. In 1993, he, his son, P, and trusts for P's two sons contributed their unencumbered E stock to BLP, a family limited partnership, in exchange for partnership interests proportionate to the fair market value of the E stock each contributed.
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From 1927 until 1993, Mr. B was an employee, officer, or director of E (an insurance company) and was a major contributor to E's success. In 1993, he, his son, P, and trusts for P's two sons contributed their unencumbered E stock to BLP, a family limited partnership, in exchange for partnership interests proportionate to the fair market value of the E stock each contributed. Mr. B's advisers had explained the estate tax advantages of placing his E stock in BLP, but the transaction was initiated to implement Mr. B's buy-and-hold philosophy with respect to the family's E stock. Specifically,…
1Opinion of the Court
Halpern, Judge:
Respondent has issued four notices of deficiency (the notices) to Samuel P. Black III (petitioner). Two were issued to him in his capacity as executor of the estate of Samuel P. Black, Jr. (Mr. Black’s estate and Mr. Black, respectively), and two were issued to him in his capacity as executor of the estate of Irene M. Black (Mrs. Black’s estate and Mrs. Black, respectively). Two notices were with respect to Federal gift tax (one with respect to Mr. Black and one with respect to Mrs. Black), each determining a deficiency in tax of $147,623 for 2001 for gifts by Mr. Black that…
2Cases cited12 opinions
- United States v. Estate of GraceSupreme Court of the United States · 1969
- Estate of Bongard v. Comm'rUnited States Tax Court · 2005
- Jane C. Guynn, of the Estate of Vena E. Calvert, Deceased v. United StatesCourt of Appeals for the Fourth Circuit · 1971
- Estate of Bahr v. CommissionerUnited States Tax Court · 1977
- Todd v. CommissionerUnited States Tax Court · 1971
7 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Estate of Turner v. Comm'rUnited States Tax Court · 2012
- Curcio v. Comm'rUnited States Tax Court · 2010
- Topsnik v. CommissionerUnited States Tax Court · 2014
- Estate of Elkins v. Comm'rUnited States Tax Court · 2013
- Carmody v. Comm'rUnited States Tax Court · 2016
18 more not listed; retrieve them via the Exa API.