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 toPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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