MARK W. SENDA AND MICHELE SENDA - Page 15

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               It is apparent from petitioner’s evasive testimony and from            
          the total record that petitioners were more concerned with                  
          ensuring that the beneficial ownership of the stock was                     
          transferred to the children in tax-advantaged form than they were           
          with the formalities of FLPs.  Indeed, petitioner, as general               
          partner, did not maintain any books or records for the                      
          partnerships other than brokerage account statements and                    
          partnership tax returns.  Those tax returns were prepared months            
          after the transfers of the partnership interests.  Thus, they are           
          unreliable in deciding whether petitioners transferred the                  
          partnership interests to the children before or after they                  
          contributed the stock to the partnerships.  The same is true of             
          the certificates of ownership reflecting the transfers of the               
          partnership interests, which were not prepared until at least               
          several weeks after the transfers.  The informality is not                  
          surprising, inasmuch as petitioners alone, individually, or on              
          behalf of their minor children were united in purpose and acted             
          without restraint by any adverse interest.  As a result, however,           
          petitioners have presented no reliable evidence that they                   
          contributed the stock to the partnerships before they transferred           
          the partnership interests to the children.  At best, the                    
          transactions were integrated (as asserted by respondent) and, in            
          effect, simultaneous.                                                       







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