115 T.C. No. 36
UNITED STATES TAX COURT
INA F. KNIGHT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
HERBERT D. KNIGHT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 11955-98, 12032-98.1 Filed November 30, 2000.
On Dec. 28, 1994, Ps established a trust of which
P-H was trustee (the management trust), a family
limited partnership (the partnership) of which the
management trust was the general partner, and trusts
for the benefit of each of Ps' two adult children (the
children’s trusts). Ps transferred three parcels of
real property used by Ps and their children and some
financial assets to the partnership. Each P
transferred a 22.3-percent interest in the partnership
to each of their children’s trusts.
The parties stipulated that the steps to create
the partnership satisfied all requirements under Texas
1 These cases were consolidated for trial, briefing, and
opinion.
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