T.C. Memo. 1999-309
UNITED STATES TAX COURT
LARRY L. SATHER, DONOR, ET AL.,1 Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 22141-97, 22142-97, Filed September 17, 1999.
22143-97, 22144-97,
22145-97, 22146-97,
469-98, 470-98,
471-98.
L, J, D, and R are brothers. L, J, and D are each
married, and each married couple has three children. R
is not married and has no children. L, J, D, their
wives, and R own S-co, a family-owned candy
distribution business. They wanted to pass S-co to the
next generation in a way that would have minimal tax
1Cases of the following petitioners are consolidated
herewith: Sandra Sather, docket No. 22142-97; John R. Sather,
docket No. 22143-97; Kathy J. Sather, docket No. 22144-97; Duane
K. Sather, docket No. 22145-97; Diane R. Sather, docket No.
22146-97; Duane K. Sather Irrevocable Trust, docket No. 469-98;
Larry L. Sather Irrevocable Trust, docket No. 470-98; and John R.
Sather Irrevocable Trust, docket No. 471-98.
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