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Tax Regs. While accepting petitioners' concession regarding the
transfers to the Kerr children, counsel for respondent argued that
additional discovery was needed to determine the nature of the
property interests that petitioners transferred to the GRAT’s
trustees. In response to these developments, the Court informed
the parties that it intended to define the property interests that
petitioners had transferred to the GRAT’s trustees, and decide the
legal question of the applicability of section 2704(b) before
conducting a trial on valuation issues. In this regard, the Court
directed the parties to proceed with informal discovery, submit a
stipulation of facts to the Court, and prepare for a partial trial,
if necessary, on the issue of the nature of the property interests
that petitioners had transferred to the GRAT’s trustees.
This matter was subsequently called for a partial trial in
Houston, Texas. The parties filed a stipulation of facts, and the
Court received testimony from Eastland, petitioner, Mary Kerr
Winters, and James Robinson Kerr. Following the aforementioned
hearings, the parties filed additional memoranda.
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