- 55 -
C. 1994 Transfers by Jean True
After Dave True died, Jean True no longer wished to be
actively involved in all the True companies. Accordingly, on
June 30 and July 1, 1994, she gave notice to her sons of her
intent to sell most of her interests in the True companies. Jean
True sold her interests to her sons at book value, pursuant to
the terms of the buy-sell agreements.
Jean True timely filed a 1994 Federal gift tax return
disclosing the transactions but treating them as sales, thereby
reporting no taxable gifts.
On January 20, 1998, respondent issued to Jean True a notice
of deficiency (1994 gift tax notice), determining that the values
of interests she sold in 1994 were higher than reported book
values. However, since issuing the 1994 gift tax notice,
respondent has conceded the reported values of interests in
Roughrider Pipeline Co., Rancho Verdad, Toolpushers Supply Co.,
and Midland Financial Corp. that were sold by Jean True in 1994.
Appendix schedule 3, infra, lists the interests sold and compares
the 1994 gift tax notice values to amounts paid by the
purchasers.
IV. Subsequent Income Tax Litigation Regarding Ranchland
Exchange Transactions
During the 1980's, the True family (except Tamma Hatten)
purchased land and operating assets to add to their ranching
operations. Each purchase took place through the same series of
Page: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 NextLast modified: May 25, 2011