- 40 - like that of the taxpayers in Hewitt v. Commissioner, 109 T.C. 258 (1997). Petitioners, during 1995, consulted with Attorney Kelley concerning income and estate tax planning. Attorney Kelley directed and assisted petitioners in setting up an FLP for each couple. Each couple also established a corporation to be the general partner of their FLP, and the individuals were made the limited partners of their respective partnerships. The general partner (the controlled corporation of each couple) had operating authority over each FLP. A limited partner’s interest could not be transferred without permission of all other partners in the FLP. Each couple contributed their Beneco stock, along with other assets, to their FLP in 1995. Attorney Kelley assisted petitioners with their donations of interests in their limited partnerships to CCF. CCF anticipated that petitioners would make gifts of interests in the FLPs in 1995 and in future years. It was understood that the transferred FLP interests would be reacquired from CCF (or other charitable donee), and irrevocable life insurance trusts were created that would be used to fund the reacquisition of the contributed interest upon each donor’s death. At the time of the contributions of the FLP interests, CCF, and later Crossmen Ministries, received FLP interests that could not be transferred without petitioners’ and their wholly ownedPage: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 NextLast modified: March 27, 2008