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Second, the estate contends that the partnership provided
continuity of management for the Padaro Lane property. We
disagree. There was no change in the continuity of management of
the Padaro Lane property after decedent’s trust transferred it to
Spindrift. Under the partnership agreement, the partnership
terminated if the general partner terminated unless the remaining
partners agreed to continue the partnership. The partnership
would terminate when decedent’s trust terminated because
decedent’s trust was the general partner. Transferring the
Padaro Lane property to Spindrift did not provide any additional
continuity of management of the property; the sole source of
management was the trust.
Third, the estate contends that it was more efficient for
decedent to give her children and grandchildren interests in the
partnership than to withdraw small undivided interests in the
Padaro Lane property from decedent’s trust and give them to her
children and grandchildren by deed. A transfer made solely to
reduce taxes and to facilitate gift giving is not considered in
this context to be made in good faith or for a bona fide purpose.
See Estate of Thompson v. Commissioner, supra at 369, 373-374,
379.
4. Comparison With the Kimbell Case
The estate asserts that the transfer by decedent’s trust of
the Padaro Lane property to Spindrift was a bona fide sale for
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