Estate of Ellie B. Williams, Deceased, Robert M. Driggers, Sr., Personal Representative, et al. - Page 15

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          transfers of stock by a corporation's two shareholders to three             
          employees were not gifts because the transfers were made in the             
          ordinary course of business and were made for adequate and full             
          consideration.  The employees had no special, personal                      
          relationship with the two shareholders.  In contrast, decedent              
          and petitioner had a close personal relationship.  In Hull, we              
          held that the taxpayer's transfer of an interest in mineral                 
          rights to a family-owned corporation in exchange for an annuity             
          payment of $15,000 per year for life was made in the ordinary               
          course of business, despite the fact that the beneficiaries of              
          the transaction were family members.  Hull differs from this case           
          because the issue there was not whether the taxpayer had donative           
          intent when she transferred property for less than its fair                 
          market value; indeed, the Commissioner stipulated that the                  
          taxpayer believed that she had made a bona fide sale.  In                   
          contrast, whether decedent had donative intent in making the 1980           
          and 1983 transfers is in dispute here.                                      
               3.   Petitioners' Partnership Theory                                   
               Petitioners argue that petitioner and decedent formed a                
          partnership and that decedent's transfers of property to him were           
          subject to that partnership.  Petitioners point out that a                  











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