Present Law And Proposals Relating to Federal Transfer Tax Consequences of Estates Freezes : Scheduled for a Joint Hearing Before the Subcommittee On Energy And Agricultural Taxation And the Subcommittee On Taxation And Debt Management of the Senate Commi
Present Law And Proposals Relating to Federal Transfer Tax Consequences of Estates Freezes : Scheduled for a Joint Hearing Before the Subcommittee On Energy And Agricultural Taxation And the Subcommittee On Taxation And Debt Management of the Senate Commi
United States. Congress. Joint Committee On Taxation
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at 297. ='3 See LTR 8805029 (Nov. 9, 1987), LTR 8806082 (Nov. 18, 1987). ^* See, e.g., T. Solberg, "Buy-Sell Agreements Can Freeze Asset Values and in Some Cases Make Them Disappear," 59 Taxes 437 (July 1981); S. Tobisman, "Estate and Gift Tax Consider- ations in Buy-Sell Agreements," 35 U.S. California Tax Institute, para. 2700 (1983). ^"•See Hoffman v. Commissioner, 2 T.C. 1160, 1187-88 (1943), acq. 1944 C.B. 13, aff'd on other issue, 148 F.2d 285 (9th Cir. 1945), cert, denied, 326 U.S. 730 (...1945); Rev. Rul. 80-186, 1980-2 C.B. 280. 36 See Bensel v. Commissioner, 36 B.T.A. 246 (1937) aff'd, 100 F.2d 639 (3d Cir. 1938) (continued services by son constituted adequate consideration for option given by father); Cobb v. Commis- sioner, 49 T.C.M. (CCH) 1364 (1985) (exchange of option for agreement to act as farm manager did not result in gift). 31-371 0-90-2 14 ties holding the options differ although the exercise price is the same. ^ ' Estate tax consequences A restriction upon the sale or transfer of property reduces its fair market value.
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