Estate of Charles E. Reichardt - Page 1

                                   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.                            

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