The United States Tax Court recently published a tax court memorandum opinion, T.C. Memo 2010-2 entitled Walter Price v. Commissioner. In Price the Tax Court held that a couple’s gifts of interest in a Nebraska limited partnership to their children did not qualify for the gift tax present interest annual exclusion under I.R.C. § 2503(b), determining that despite distributions of nearly $530,000 in the six years following the initial gift because the Price’s failed to show that the gifts had an unrestricted and noncontingent right to immediate use. For a link to the full Price v. Commissioner opinion, see our website at www.pvwlaw.com.
Link for website: http://www.ustaxcourt.gov/InOpHistoric/PRICE3.TCM.WPD.pdf
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