Bianca Gross v. Commissioner analyzed

Steve Akers (Bessemer Trust, Dallas, Texas) has written an article entitled Tax Court Rejects Indirect Gift Attack for Gift of Partnership Interest At Least 11 Days After Contribution of Stock Portfolio to Partnership, Bianca Gross v. Commissioner, T.C. Memo 2008- 221 (September 29, 2008), abanet.org.

This article analyzes the opinion and holding of the tax court in Gross v. Commisioner. It examines the tax consequences of creating a partnership and then gifting securities into the partnership.