- 73 -
C. Conclusion
Because petitioners have failed to show that their
computation of the value of the children’s obligation to pay any
2035 tax is reliable, we do not accept it as establishing any
proceeds received by petitioners and reducing the value of the
net gifts made by them.
VIII. Conclusion
The fair market value of the gifted interest on the date of
the gift was $9,883,832 ($4,941,916 for each half thereof).
Petitioners are entitled to an aggregate charitable contribution
deduction under section 2522 for the transfer to CFT in the
amount of $415,019 ($207,510 apiece).
To reflect the foregoing,
Decision will be
entered under Rule 155.
Reviewed by the Court.
WELLS, COHEN, SWIFT, GERBER, COLVIN, GALE, and THORNTON,
JJ., agree with this majority opinion.
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