Heckerman v. U.S. (filed 7/27/09)

In this U.S. District Court case, the Court determined that both gifts of cash to a LLC and gifts of LLC interests were indirect gifts, due to the fact that the transfer to the LLC was on the same day as the gift of the LLC interests. Also, a transfer of cash to a LLC and gifts of the LLC interests were an “integrated transaction” and the step transaction doctrine was applied.


Note: Full-text of this case can be found at:
http://www.calsgiftplanning.org/giftlaw/code.jsp?WebID=GL2005-0833&Cat=4&ID=320