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enter a decision with respect to him consistent with the decision
to be entered with respect to Teresa. See Rule 123(a).
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the year at issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
The deficiencies in income tax and additions to tax
determined by respondent against petitioners are as follows:
Additions to Tax
Sec. Sec. Sec.
Docket No. Petitioner Year Deficiency 6653(a)(1) 6653(a)(2) 6661(a)
345-92 Tracy 1985 $362,594.10 $18,129.71 * $90,649
352-92 Teresa and Davis1985 365,924.20 18,296.21 * 91,481
900-92 Parkers 1985 1,482,266.80 74,113.34 * 370,567
* 50 percent of the interest due on the amount of the deficiency.
The Parkers and respondent have entered into a stipulation
of settled issues, which the Court accepts. Certain other issues
have otherwise been resolved. The issues remaining for decision
can be divided into several groups. The first group is as
follows: (1) Whether Parker made gifts to the daughters that
resulted in the daughters’ having interests in a certain joint
venture in January 1980, (2) whether Parker owned the interest in
the joint venture and made gifts to the daughters in March 1981
of notes resulting from a sale of that interest, or (3) whether
Parker made gifts of the proceeds from those notes to the
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