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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