- 2 -
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein. At the time the petition was filed in this
case, petitioners resided in Baton Rouge, Louisiana.
FINDINGS OF FACT
Petitioners are husband and wife and have four children.
Prior to December 1988, Mr. Rabenhorst was a principal
shareholder of Rabenhorst Life Insurance Co., Inc. (RLIC),
located in Louisiana. For Federal estate and gift tax planning
purposes, Mr. Rabenhorst desired to shift ownership of RLIC to
his children. In furtherance of this objective, he initiated a
sequence of yearly gifts of RLIC stock to his children in 1988.
On December 12, 1988, Mr. Rabenhorst transferred a total of 3,048
shares of RLIC stock to his four children (the 1988 stock
transfer). Each donee received 762 shares. On their timely
filed Federal gift tax returns for 1988, petitioners elected,
pursuant to section 2513,1 to treat each gift as having been made
one-half by Mr. Rabenhorst and one-half by Mrs. Rabenhorst. On
his Federal gift tax return for 1988, Mr. Rabenhorst reported a
tax due in the amount of $1,465.11. On her Federal gift tax
return for 1988, Mrs. Rabenhorst reported a tax liability of
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011