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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