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THORNTON, Judge: Respondent determined a $168,577
deficiency in petitioner’s Federal gift tax for calendar year
1991. The issues for decision are: (1) The characterization,
for gift tax purposes, of petitioner’s transfers of certain real
estate and stock into a family partnership of which petitioner is
50-percent owner and his two sons are each 25-percent owners;
(2) the fair market value of the transferred real estate
interests; and (3) the amount, if any, of discounts for
fractional or minority interests and lack of marketability that
should be recognized in valuing the transferred interests in the
real estate and stock.
Section references are to the Internal Revenue Code as in
effect on the date of the gifts. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
The parties have stipulated some of the facts, which are so
found.
Petitioner is married to Mary Ruth Shepherd and has two
adult sons, John Phillip Shepherd (John) and William David
Shepherd (William). When he filed his petition, petitioner
resided in Berry, Alabama.
Petitioner’s Acquisition of Interests in Land and Bank Stock
Beginning in 1911, petitioner’s grandfather–-at first singly
and later with petitioner’s father--acquired a great deal of land
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