- 14 -
We hold that a sufficient quantity of the benefits and
burdens of ownership passed to the Church so that the transaction
was closed for Federal income tax purposes when the contract for
deed was signed in 1994. Petitioners made a completed gift in
1994. Accordingly,
Decision will be
entered for petitioners.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011