118 T.C. No. 14 UNITED STATES TAX COURT CHRISTINE M. HACKL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent ALBERT J. HACKL, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 6921-00, 6922-00. Filed March 27, 2002. In 1995 and 1996, Ps A and C made gifts to their children and grandchildren of membership units in Treeco, LLC, a limited liability company. Treeco had previously been organized by A to hold and operate tree farming properties. This timberland had been purchased by A to provide investment diversification in the form of long-term growth and future income. Treeco was governed by an Operating Agreement which set forth the rights and duties conferred on members and the manager and which designated A as manager. At the time of the gifts, it was correctly anticipated that Treeco and its successor entities would generate losses and make no distributions for a number of years. Held: The gifts of Treeco units made by Ps fail to qualify for the annual gift tax exclusion provided in sec. 2503(b), I.R.C.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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