114 T.C. No. 9 UNITED STATES TAX COURT ESTATE OF CHARLES E. REICHARDT, DECEASED, WILLIAM D. REICHARDT, INDEPENDENT EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1224-98. Filed March 1, 2000. Decedent (D) had two children, C and W. On June 17, 1993, D formed a revocable family trust (the trust) and a family limited partnership (the partnership). The trust was the general partner of the partnership. D, C, and W were named cotrustees, but only D performed any functions as trustee. D transferred his residence and all of his other property (except for his car, personal property, and some cash) to the partnership through the trust. D’s transfer was not a bona fide sale for full and adequate consideration. On Oct. 22, 1993, D gave C and W each a 30.4-percent interest in the limited partnership. D retained possession and enjoyment of and the right to income from the property he transferred to the partnership until he died on Aug. 21, 1994.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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