Estate of Robert V. Schuler - Page 5




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          duplicate the first step; that is, to make joint transfers of               
          Sigco stock equal in value to $20,000 to each of decedent's                 
          children and grandchildren.  The third step in their scheme was             
          for certain of decedent's children to transfer the shares that              
          they had received to four of their siblings, including to Jay and           
          his children.2                                                              
               The first step to transfer the Minn-Kota stock was for                 
          George and his wife to make joint gifts of Minn-Kota stock valued           
          at $20,000 to each of their children and grandchildren in                   
          December 1994 and January 1995.  The second step was for decedent           
          and his wife to duplicate the first step; that is, to transfer in           
          each year $20,000 of Minn-Kota stock to George and his wife and             
          their children.  The third step was for certain of George's                 
          children and their spouses to transfer the stock in amounts equal           
          in value to $10,000 to Jody and his wife, Holly, and to their               
          children, George M. Schuler IV (George IV) and William.3                    
               1994 Transfers of Sigco Stock                                          
               On December 28, 1994, in addition to transferring shares of            


               2Mr. Middaugh's notes with respect to this plan stated that            
          the "IRS could claim Step 3 is a step transaction - would be                
          highly likely if 1) there was a written agreement to do so, and             
          2) if it was done at the same time.  Suggest it be voluntary and            
          at the end of 1995 at earliest."  The third step had not been               
          executed at the time of trial.                                              
               3Mr. Middaugh made a note similar to the one in supra note 2           
          with respect to this step of the scheme.  At the time of trial,             
          "Step 3" had not been executed.                                             





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