No Gift Tax Due When Partnership Was Formed Two Days Before Death

Business Valuation Update BVLaw
Legal and Court Case Update
January 18, 2000

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0291 General Farms, Primarily Livestock and Animal Specialties
112990 All Other Animal Production
estate and gift taxation
income approach, discount for lack of marketability (DLOM), market approach, partnership agreement, discount for lack of control (DLOC), undivided interest
Church v. United States (I)
2000 U.S. Dist. LEXIS 714
US
Federal Court
Texas
United States District Court
Bruce Johnson (for plaintiff)
Garcia

Summary

The U.S. District Court for the Western District of Texas rejected the IRS' position that gift tax was due on the formation of a family limited partnership formed two days before the decedent's death.

See Also

Church v. United States (I)

Full Text of Court Cases
January 18, 2000

At issue is whether a partnership transaction was entered into for no purpose other than to reduce the taxation of Mrs. Church's estate.