Christine M. Hackl - Page 10




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          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 as              






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