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               Petitioners argue that there is sufficient evidence showing            
          that they first funded the partnerships and then transferred the            
          partnership interests to the children and direct our attention to           
          the letters that they faxed to their accountant after they had              
          funded the partnerships.  Those faxes, however, establish only              
          that petitioners had funded the partnerships.  They do not show             
          what the partnership ownership interests were immediately before            
          the funding or how the stock was allocated among the partners’              
          capital accounts at the time of the funding.  Moreover, the fax             
          seeking advice with respect to the SFLP II partnership interests            
          was dated 2 days after petitioners had allegedly transferred the            
          partnership interests to the children.                                      
               On this record, we conclude that the value of the children’s           
          partnership interests was enhanced upon petitioners’                        
          contributions of stock to the partnerships.  Accordingly, we hold           
          that petitioners’ transfers of stock to SFLP I and SFLP II on               
          December 28, 1998, and December 20, 1999, respectively, were                
          indirect gifts of the stock to the children for purposes of                 
          sections 2501 and 2511.  Respondent has conceded that the                   
          January 31, 2000, gifts were gifts of partnership interests and             
          not gifts of stock.  The gift tax thus shall be determined on the           
          value of the stock rather than on the value of the partnership              
          interests transferred.                                                      

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