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Barton T. Sprunger and Mark J. Richards, for petitioners.
Russell D. Pinkerton, for respondent.
OPINION
NIMS, Judge: By separate statutory notices, respondent
determined a deficiency in the 1996 Federal gift tax liability of
petitioner Christine M. Hackl (Christine Hackl) in the amount of
$309,866 and in the 1996 Federal gift tax liability of Albert J.
Hackl, Sr. (A.J. Hackl), in the amount of $309,950. Petitioners
each timely filed for redetermination by this Court, and, due to
an identity of issues, the cases were consolidated for purposes
of trial, briefing, and opinion. In accordance with stipulations
of partial settlement filed by the parties, the sole matter
remaining for decision is whether gifts made by petitioners of
units in a limited liability company qualify for the annual
exclusion provided by section 2503(b).
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the year at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Background
These cases were submitted fully stipulated pursuant to Rule
122, and the facts stipulated are so found (except as noted in
footnote 1). The stipulations of the parties, with accompanying
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