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MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: By notice of deficiency dated May 25, 2001
(the notice of deficiency), respondent determined a deficiency in
Federal gift tax for calendar year 1997 with respect to
petitioner in the amount of $328,317. Petitioner timely filed a
petition for redetermination. The dispute involves the value of
interests in a family limited partnership transferred by
petitioner to a family trust.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect on the date of the transfers, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. All dollar amounts have been rounded to the nearest
dollar.
FINDINGS OF FACT
Some facts are stipulated and are so found. The stipulation
of facts, with accompanying exhibits, is incorporated herein by
this reference. At the time he filed the petition, petitioner
resided in Grosse Pointe Woods, Michigan.
Formation of the Trust and the Partnership
On November 25, 1997 (the valuation date), petitioner, as
settlor, and petitioner’s wife, as trustee, executed a trust
agreement creating the Peracchio Family Trust (the trust). On
the same day, petitioner, the trust, and petitioner’s son, John
R. Peracchio, executed an agreement of limited partnership (the
partnership agreement) with respect to Peracchio Investors, L.P.,
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Last modified: May 25, 2011