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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