Taxpayer Receiving LP Interest of Lesser Value Did Not Make Gift at FLP Inception

BVResearch Pro
Willamette Insights
November 1, 2001
Kelly Wright

Summary

In the Estate of W.W. Jones II v. Commissioner [T.C. Memo 2001-121 (March 6, 2001)], the Internal Revenue Service (ôthe Serviceö) claimed a deficiency of $4,412,527 in the 1995 fed-eral gift tax of W.W. Jones II. There were four issues facing the Court ...
Taxpayer Receiving LP Interest of Lesser Value Did Not Make Gift at FLP Inception
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