T.C. Memo. 2003-280 UNITED STATES TAX COURT PETER S. PERACCHIO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10470-01. Filed September 25, 2003. P transferred limited partner interests in a family limited partnership (PT) to a family trust (T) pursuant to two separate transactions. In one of the transactions, P transferred a 45.47-percent limited partner interest to T for no consideration. In the other transaction, P transferred a 53.48-percent limited partner interest to T in exchange for T’s promissory note in the amount of $646,764. Held: Fair market value of the transferred PT interests determined. See sec. 2512, I.R.C. Eric M. Nemeth, Michael J. Mulcahy, and Brian C. Bernhardt, for petitioner. John W. Stevens, for respondent.Page: 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