116 T.C. No. 11
UNITED STATES TAX COURT
ESTATE OF W.W. JONES II, DECEASED, A.C. JONES IV, INDEPENDENT
EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13926-98. Filed March 6, 2001.
D formed a family limited partnership (JBLP) with
his son and transferred assets including real property,
to JBLP in exchange for a 95.5389-percent limited
partnership interest. D also formed a family limited
partnership (AVLP) with his four daughters and
transferred real property to AVLP in exchange for an
88.178-percent limited partnership interest. D’s son
contributed real property in exchange for general and
limited partnership interests in JBLP, and the
daughters contributed real property in exchange for
general and limited partnership interests in AVLP. All
of the contributions were properly reflected in the
capital accounts of the contributing partners.
Immediately after formation of the partnerships, D
transferred by gift an 83.08-percent limited
partnership interest in JBLP to his son and a
16.915-percent limited partnership interest in AVLP to
each of his daughters.
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