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issue have been paid, where, in response to the notices of
deficiency, petitioners sent the Internal Revenue Service
remittances and directed that the remittances be applied to the
deficiencies in issue, and, subsequently, respondent made an
erroneous nonrebate refund of those remittances to petitioners.
All section references are to the Internal Revenue Code, as
amended, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Background
The parties submitted the instant case fully stipulated,
without trial, pursuant to Rule 122. The parties’ stipulations
of facts are hereby incorporated in this opinion by this
reference and are found as facts in the instant case.
Petitioners W. August Hillenbrand and Nancy K. Hillenbrand
are husband and wife. When the petition was filed, they were
residents of Batesville, Indiana. During the years in issue,
petitioner W. August Hillenbrand was the chief executive officer
of Hillenbrand Industries, Inc.
During 1993, 1994, and 1995, petitioners made substantial
gifts to their children and son-in-law. In 1993, 1994, and 1995,
petitioners also made contributions to trusts commonly referred
to as “Grantor Retained Annuity Trusts” (GRATs). Petitioners
each filed Federal gift tax returns for 1993, 1994, and 1995.
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