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

Business Valuation Update BVLaw
Legal and Court Case Update
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 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.

See Also

Hackl v. Commissioner (I)

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