Estate of Morton B. Harper, Deceased, Michael A. Harper, Executor - Page 1

                                 T.C. Memo. 2002-121                                  

                               UNITED STATES TAX COURT                                

               ESTATE OF MORTON B. HARPER, DECEASED, MICHAEL A. HARPER,               
                               EXECUTOR, Petitioner v.                                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 19336-98.            Filed May 15, 2002.                    

                    HFLP, a limited partnership, was established in                   
               1994 and was capitalized by the contribution thereto by                
               D of the majority of his assets.  D was initially named                
               as the sole limited partner and his children, M and L,                 
               were designated as general partners.  D subsequently                   
               gave to M and L 24- and 36-percent limited partnership                 
               interests, respectively.  At his death in 1995, D                      
               continued to hold a 39-percent limited partnership                     
               interest in HFLP.                                                      
                    Held:  The property contributed by D to HFLP is                   
               includable in his gross estate pursuant to sec.                        
               2036(a), I.R.C.                                                        
                    Held, further, value of the assets to be included                 
               in the gross estate determined.                                        

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