Tracy P. Streber, F.K.A. Tracy C. Parker, et al. - Page 4

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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                  
               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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