- 10 - petitioners pursuant to section 2513. Petitioners also treated the gifts as qualifying for the annual exclusion of section 2053(b). Respondent did not issue notices of deficiency to petitioners for 1995. On January 18, 1996, Treeco purchased a third property in Flager County, Florida (Flager County Farm), using $5,750,436 of the LLC’s cash and securities. The Flager County Farm consisted of 8,382 acres and contained merchantable timber valued at $23,638 at the time of sale. Thereafter, on March 5, 1996, petitioners continued their program of gifting Treeco units with the gifts that are at issue in this litigation. Petitioners once again each gave 500 voting and 750 nonvoting units in Treeco to each of their eight children and to the spouses of such children. Also on that date, A.J. Hackl created the Albert James Hackl Irrevocable Trust (Grandchildren’s Trust), for the benefit of petitioners’ minor grandchildren. At that time, petitioners each transferred 31,250 nonvoting units in Treeco to the Grandchildren’s Trust, representing 1,250 units for each of their 25 minor grandchildren. Three of petitioners’ children were named as trustees of the Grandchildren’s Trust and in that capacity executed an acceptance of the Treeco Operating Agreement. Petitioners reported the gifts made in 1996 on timely filed gift tax returns and elected on those returns to treat the gifts asPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011