Two rulings uphold Hackl v. Comm'r, confirming that gifts of interests in closely held companies don't qualify for the annual exclusion
In Price v. Comm'r, T.C. Memo 2010-2, the Tax Court refused to reconsider its holding in Hackl v. Comm'r, 118 T.C. 279 (2002), and held that the taxpayers' gifts of partnership interests didn't qualify for the annual exclusion due to the restrictions in the partnership agreement.
Walter and Sandra Price forme