Summary
In November 1992, the Petitioners gifted shares of St. Edward Management Co. (the "Company") common stock to their children.
See Also
Janda v. Commissioner
In November 1992, the Petitioners gifted shares of St. Edward Management Company (the "Company") common stock to their children. Each gift represented approximately 5.3% of the outstanding shares of common stock. St. Edward Management Co. owned 94.6% of the common stock of the Bank of St. Edward (the Bank), a bank located in a small agricultural community in Nebraska.