Walter R. Ripley, Donee-Transferee of Mildred M. Ripley, Donor, and Melynda H. Ripley, Donee-Transferee of Mildred M. Ripley, Donor - Page 1

                                   105 T.C. No. 23                                    


                               UNITED STATES TAX COURT                                


           WALTER R. RIPLEY, DONEE-TRANSFEREE OF MILDRED M. RIPLEY, DONOR,            
          ANDMELYNDA H. RIPLEY, DONEE-TRANSFEREE OF MILDRED M. RIPLEY, DONOR,         
             Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent              


               Docket No. 26209-93.                 Filed November 8, 1995.           


                    In 1983 the donor made gifts of parcels of real                   
               estate valued at $93,300 to Ps, husband and wife, as                   
               tenants in common.  During the same year the donor made                
               gifts of other parcels of real estate to a different                   
               donee.  Controversy arose between the donor and R as to                
               the valuation of the gifts to the other donee.  As a                   
               result of the donor's timely consents, the 3-year                      
               period of limitations for assessment, sec. 6501(a),                    
               I.R.C., was extended to Apr. 18, 1990.  On Feb. 9,                     
               1990--68 days prior to expiration of the extended                      
               period--R sent the donor a notice of gift tax                          
               deficiency.  On Feb. 25, 1992, a stipulated decision                   
               was entered by this Court based upon a computation that                
               left intact the $93,300 valuation of the gifts to Ps                   
               but significantly increased the value of the gifts to                  





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