- 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