On June 10, 2020, the Tax Court issued a Memorandum Opinion in the case of Nelson v. Commissioner (T.C. Memo. 2020-81). The primary issue before the court in Nelson v. Commissioner was whether the limited partnership interests, transferred on December 31, 2008, and January 2, 2009, were fixed dollar amounts or percentage interests, which in turn affected whether the gifts were complete when transferred, which in turn affected inclusion on the petitioners’ income tax returns for certain years. Background to Longspar in Nelson v. Commissioner Longspar Partners, Ltd. was formed in October 2008, as a Texas limited partnership. It was formed as part of a tax planning strategy to (1) consolidate and protect assets, (2) establish a mechanism to make gifts without fractionalizing interests, and (3) ensure that petitioner-wife’s father’s holding company (owning 7 subsidiary Caterpillar dealerships) remained in business and under family control. The petitioners are Longspar’s sole general…