The 2002 Tax Court case, Hackl v. Commissioner,1 surprised some and the affirmance by the Seventh Circuit Court of Appeals in 2003 shocked even more although Hackl did not depart markedly from prior authority.2 Two more recent cases, Price v. Commissioner3 and Wimmer v. Commissioner4 have provided more detailed guidance on the bounds of what is a “present interest” in the context of transfers to family members involving an entity.