Baine P. and Mildred C. Kerr - Page 16




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          Petitioners further reported that 95 percent of the fair market             
          value of the KFLP class B limited partnership interests that they           
          transferred to the GRAT’s trustees was attributable to their                
          retained annuities, while the remaining 5 percent (or $38,050               
          (rounded)) represented the amount of their taxable gifts to the             
          remainder beneficiaries of the GRAT’s.                                      
               Petitioners computed the fair market value of the KILP class           
          B limited partnership interests that they transferred to their              
          children in 1994 and 1995 by applying a 25-percent discount for             
          lack of liquidity or marketability.                                         
          Respondent's Determinations                                                 
               Respondent issued a notice of deficiency to petitioner Baine           
          P. Kerr determining deficiencies of $698,401 and $10,024 in his             
          Federal gift taxes for 1994 and 1995, respectively.  Respondent             
          issued a notice of deficiency to petitioner Mildred C. Kerr                 
          determining deficiencies of $698,401 and $10,024 in her Federal             
          gift taxes for 1994 and 1995, respectively.  Respondent determined,         
          among other things, that petitioners had understated the values of          
          both the KFLP interests that they had transferred to the GRAT’s             
          trustees in 1994 and the values of the KILP interests that they had         
          transferred to their children in 1994 and 1995, as follows:                 











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