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LTV Corp. v. Commissioner, 64 T.C. 589, 595 (1975) (quoting
California v. San Pablo & Tulare R.R. Co., 149 U.S. 308, 314
(1893)).
Accordingly, we conclude that petitioner is liable for no
gift taxes on his transfers of overriding royalties to the
children’s trusts and that, moreover, he made no taxable gifts of
mineral interests to his wife. Our ruling renders moot
respondent’s determination that petitioner is liable for
additions to tax under sections 6651(a)(1) and 6653(a).
To reflect the foregoing,
Decision will be entered
for petitioner.
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