- 3 -
Donee Date Amount
1. Doris K. Rickman 1/1/90 $10,000
10/16/90 227,583
2. Janet R. Tipton 10/16/90 207,583
10/16/90 16,255
3. James O. Tipton 10/16/90 20,000
Janet R. Tipton and James O. Tipton are identified as decedent
and Mr. Rickman's daughter and son-in-law, respectively.
Form 709, lines 12 through 18, permit a taxpayer to elect to
split gifts with his or her spouse as prescribed under section
2513; i.e., to have gifts made by the taxpayer and his spouse to
third parties during the calendar year considered as made one-
half by each. Lines 12 through 17 of the Form 709 filed on
behalf of Mr. Rickman indicate that gifts made by Mr. Rickman
during the taxable period would be split with decedent. In
particular, decedent is identified by name and Social Security
number, and it is acknowledged that Mr. Rickman was married to
decedent during the taxable period, and that a gift tax return
will be filed by decedent for the same period. However, line 18,
which provides space for decedent's signature signifying her
consent to the gift-splitting election, was not signed on
decedent's behalf. The only marks on line 18 are the handwritten
letters "SRB".3
3 Although the parties agree that the letters "SRB" were
entered by one of respondent's examiners, they disagree as to
their meaning. Respondent contends that the letters signify that
the spouse's return is in the same batch of returns as the return
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011