- 2 -
Docket No. 1993 1994 1995
16269-99 $1,059 $3,176 $19,431
16271-99 24,436 5,663 -0-
16272-99 24,058 2,654 -0-
16273-99 104,847 4,867 -0-
After concessions by the parties, the remaining issue for
decision is whether petitioners must recognize a gain on the
transfer of assets to Seggerman Farms, Incorporated, under
section 357 to the extent that the amount of liabilities that
were assumed plus the amount of liabilities to which the property
was subject exceeds the total of the adjusted basis of the
property that was transferred to the corporation.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
These cases were submitted fully stipulated under Rule 122.
The stipulated facts are incorporated as our findings by this
reference.
Petitioners Ronald and Sally Seggerman, Craig and Linda
Seggerman, and Michael Seggerman, hereinafter collectively
referred to as petitioners, resided in Illinois at the time they
filed their petitions. Petitioner Seggerman Farms, Incorporated
(Seggerman Farms), was an Illinois corporation, and its principal
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011