In Uncategorized on 11/06/2017 at 17:14

Bob was TX Inventor of the Year one year, invented a fix for the Space Shuttle post-Challenger, had 400 patents issued or applied for, and was the go-to guy at National Couplings, producer of pneumatic and hydraulic subsea couplers.

Although he never graduated from college, Bob “…was the company’s vice president and the manager at its manufacturing facility. He was in charge of manufacturing, engineering, intellectual property work, and trademarks> 2017 T. C. Memo. 218, at p. 3.

Angela was his wife of fifty years, and a homemaker.

National Couplings got sold, Bob retired into the Golden Years, with plenty of gold.

Alas, Bob found himself with a UT grad lawyer who rigged up a Sub S collapsed into a FLP, with a big discount for the cash and stock Bob and Angela accumulated from years of toil and uncoupling from National Couplings.

Bob and Angela swim into the ken of Judge Goeke, unraveller of mix-and-match dodges. Here’s Robert E. Smith, III and Angela K. Smith, 2017 T. C. Memo. 218, filed 11/6/17.

The story was that Bob had a patent (or maybe it still belonged to National Couplings) for a lawn sprinkler that dispersed water, fertilizer and insecticide, and he was awaiting the patent so he could start selling it. So he created the Sub S to go into business.

But the Sub S collapsed into the FLP in the same year, while patents take months, if not years, to get registered.

Judge Goeke finds the sprinkler story too thin to support Bob’s very hefty discounts for the assets that went from the Sub S to the FLP, that Bob had control of the assets throughout, and the whole thing was a dodge to create a loss to offset the bodacious gains on Bob’s cash-out from National Couplings.

Unfortunately, Angela kept good notes of all the tax shenanigans. Those got in on the trial, undercut reliance on the UT grad expert, and set up the chops.


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