Walter R. Ripley, Donee-Transferee of Mildred M. Ripley, Donor, and Melynda H. Ripley, Donee-Transferee of Mildred M. Ripley, Donor - Page 3

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          of transferee liability prescribed by section 6901(c)(1)1                   
          expired, and (2) the amount of petitioners' transferee liability            
          under section 6324(b).                                                      
               The liability at issue results from gifts made by Mildred M.           
          Ripley (donor) in 1983 to her son, petitioner Walter R. Ripley              
          and petitioner Melynda H. Ripley, Walter's wife.  At the time the           
          joint petition in this case was filed, petitioners resided in               
          Greenville, Virginia.                                                       
               On December 30, 1983, the donor made a gift to petitioners,            
          as tenants in common, of two parcels of real estate located in              
          Jacksonville, Florida, which then had a total value of $93,300.             
          Petitioners thus became transferees of the donor, as defined in             
          section 6901(h).  That same year, the donor made another gift of            
          real property to her son Joseph.                                            
               On her gift tax return for 1983, filed in 1984, she reported           
          the value of the property given to petitioners as $93,300, and              
          the value of the property given to Joseph as $84,139.  On                   
          examination, the IRS took the position that the value of the                
          property given to Joseph should be substantially increased.                 
               Within the 3-year limitations period prescribed by section             
          6501(a), the donor and respondent signed a Form 872, Consent to             
          Extend the Time to Assess Tax.  Subsequent timely consent                   


          1 Unless otherwise indicated, all section references are to                 
          the Internal Revenue Code in effect at the time of the donor's              
          gifts.                                                                      




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