Tax Law Update

Hackl upheld: Gifts of interests in closely held companies do not qualify for annual exclusion In Price v. Commissioner, TC 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 did not qualify for the annual exclusion due to the restrictions in the partnership agreement. Walter M. and Sandra

David A. Handler, partner in the Chicago office of Kirkland & Ellis LLP, and Alison E. Lothes, as | Mar 01, 2010

Hackl upheld: Gifts of interests in closely held companies do not qualify for annual exclusion — In Price v. Commissioner, TC 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 did not qualify for the annual exclusion due to the restrictions in the partnership agreement.

Walter M. and Sandra K. Price formed Price Investments Limited

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