Ina F. Knight - Page 11




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          D.   Federal Tax Returns                                                      
               Petitioners filed Federal gift and generation-skipping                   
          transfer tax returns for 1994.  Both petitioners reported that                
          they had given a 22.3-percent interest in the partnership to each             
          of the children’s trusts.                                                     
               The partnership filed Forms 1065, U.S. Partnership Return of             
          Income, for 1995, 1996, and 1997.  The management trust and each              
          of the children’s trusts filed Forms 1041, U.S. Income Tax Return             
          for Estates and Trusts, for 1995, 1996, and 1997.                             
                                        OPINION                                         
          A.   Contentions of the Parties                                               
               The parties agree that the starting point for valuing                    
          petitioners’ gifts to their children’s trusts is the fair market              
          value of the assets petitioners transferred to the partnership                
          (i.e., $2,081,323), but they disagree about which discounts                   
          apply.                                                                        
               Respondent contends that petitioners’ family limited                     
          partnership should be disregarded for gift tax valuation                      
          purposes.  Thus, respondent contends that the fair market value               
          of each of the gifts is $450,086; i.e., 22.3 percent of the fair              
          market value of the real property and financial assets given by               
          petitioners, discounted for selling expenses and built-in capital             
          gains.                                                                        








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