Estate of Bies v. Commissioner

T.C. Memo. 2000-338 (2000)

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Estate of Bies v. Commissioner

United States Tax Court
T.C. Memo. 2000-338 (2000)

Facts

Over the course of 10 years, Marie A. Bies made annual transfers of stocks in a closely held family business to her sons Albert and Gregory, her grandson James (collectively, the sons), and their wives, Gayle, Loretta, and Cheryl (collectively, the wives). Each year, Marie transferred $10,000 worth of stocks to each recipient, including Albert, Gregory, Gayle, and Loretta from 1985 through 1995, and adding James and Cheryl from 1991 through 1995. Marie’s attorney, Richard Grayson, simultaneously prepared the certificates that transferred the stocks from Marie to the recipients and the certificates that then transferred the stocks from the wives to the sons. Marie did not file a gift-tax return for any of the gifts, and her estate (plaintiff) did not report any taxable gifts on the estate-tax return. The Internal Revenue Service (IRS) (defendant) determined that this arrangement of transfers was substantially a series of indirect transfers to the sons. Since the amounts transferred to the sons were over the annual gift-tax exclusions, gift taxes were owed. The estate appealed.

Rule of Law

Issue

Holding and Reasoning (Parr, J.)

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