T.C. Memo. 2005-126 UNITED STATES TAX COURT ESTATE OF CHARLES PORTER SCHUTT, DECEASED, CHARLES P. SCHUTT, JR., AND HENRY I. BROWN III, CO-EXECUTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19208-02. Filed May 26, 2005. S1 and S2, Delaware business trusts, were formed in 1998 and were capitalized by the contribution thereto of stock by D through a revocable trust and by WTC as trustee of various trusts created for the benefit of D’s children and grandchildren. At his death in 1999, D held through the revocable trust a 45.236-percent interest in S1 and a 47.336-percent interest in S2. Held: D’s transfers of stock to S1 and S2 were bona fide sales for adequate and full consideration within the meaning of secs. 2036(a) and 2038, I.R.C., such that the value of the transferred assets is not included in his gross estate under these statutes. John W. Porter, W. Donald Sparks II, and Michael R. Stein, for petitioner. Gerald A. Thorpe, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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