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PIERRE v. COMMISSIONER OF INTERNAL REVENUE

No. 753-07.

133 T.C. No. 2

SUZANNE J. PIERRE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed August 24, 2009.

Attorney(s) appearing for the Case

Kathryn Keneally and Meryl G. Finkelstein, for petitioner.

Lydia A. Branche, for respondent.

WELLS, Judge:1

Respondent determined deficiencies of $1,130,216.11 and $24,969.19 in petitioner's Federal gift tax and generation-skipping transfer tax for 2000 and 2001, respectively. The issue to be decided is whether certain transfers of interests in a single-member limited liability company (LLC) that is treated as a disregarded entity pursuant to sections 301.7701-1 through 301.7701-3, Proced. & Admin. Regs.,

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