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115 T.C. No. 30
UNITED STATES TAX COURT
J. C. SHEPHERD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2574-97. Filed October 26, 2000.
P transferred to a newly formed family partner-
ship, of which P is 50-percent owner and his two sons
are each 25-percent owners, (1) P’s fee interest in
timberland subject to a long-term timber lease and
(2) stocks in three banks.
Held: P’s transfers represent separate indirect
gifts to his sons of 25 percent undivided interests in
the leased timberland and stocks. Held, further, the
fair market value of petitioner’s gifts determined.
David D. Aughtry, James M. Kane, and Howard W. Neiswender,
for petitioner.
Robert W. West, for respondent.
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