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.
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