United States Ninth Circuit
Estate of Petter v. Commissioner of Internal Revenue, 10-71854
In a dispute involving the scope of Treasury Regulation section 25.2522(c)-3(b)(1) and arising from the transfer of membership units in an LLC partly as a gift and partly by sale to two trusts with simultaneous gifts of LLC units to two charitable foundations under a reallocation clause, judgment of the trial court is affirmed where Section 25.2522(c)-3(b)(1), upon trigger of the reallocation clause, does not bar a charitable deduction equal to the value of the additional units the foundations will receive.
Appellate Information
- Decided 08/04/2011
- Published 08/04/2011
Judges
- BYBEE
Court
- United States Ninth Circuit
Counsel
- For Appellant:
- Andrew M. Weiner, John W. Porter