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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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