Hackl v. Commissioner (I)

Full Text of Court Cases
March 27, 2002
0811 Timber Tracts
113110 Timber Tract Operations
estate and gift taxation
gift tax, limited liability company, internal revenue service (IRS)

Hackl v. Commissioner (I)
118 T.C. 279, 118 T.C. No. 14, 2002 U.S. Tax Ct. LEXIS 16
Federal Court
United States Tax Court


The issue was whether the gifts were present interests or future interests under Section 2503(b) of the tax code.
Hackl v. Commissioner
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See Also

Lack of Present Economic Benefit Results in Finding of Future Interest

In the April 2002 issue of Shannon Pratt's Business Valuation Update, Owen Fiore and Erin Wilms discussed various attacks by the IRS on pass-through entities.

Gifts of Future Interest Do Not Qualify for Sec. 2503(b) Exclusion

The full Tax Court considered whether gifted LLC units subject to a restrictive operating agreement were gifts of a present or future interest in the gifted property for the purposes of the annual gift tax exclusion.