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ROBERT L. PETERSON IRREVOCABLE TRUST #2 v. COMMISSIONER

Docket Nos. 29263-81, 29264-81, 29265-81, 29266-81, 29267-81, 29268-81, 29269-81, 29270-81, 29271-81.

51 T.C.M. 1300 (1986)

T.C. Memo. 1986-267

Robert L. Peterson Irrevocable Trust #2 for the Benefit of Susan P. Peterson, Transferee, Union Bank and Trust Company, Trustee, et al. v. Commissioner.

United States Tax Court.

July 1, 1986.

Attorney(s) appearing for the Case

T. Geoffrey Lieben, Nick R. Taylor, and James W.R. Brown, 1000 Woodmen Tower, Omaha, Neb., for the petitioners. J. Anthony Hoefer, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

These consolidated cases arise from petitioner Robert L. Peterson's gifts of 50,000 shares of stock (or the sales proceeds thereof) to his two children and to trusts for their benefit. Before making the gifts, Peterson had entered into a contract to sell the stock for $13 per share. Peterson elected to "split" the gifts with his wife, petitioner G. Virginia Peterson, pursuant to section 2513.

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