Tracy P. Streber, F.K.A. Tracy C. Parker, et al. - Page 5

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          daughters in 1985.2  If issue (1) is answered affirmatively, then           
          (A) gain is recognized to the daughters, not Parker, in 1985,               
          (B) there is no issue as to the amount of gain recognized to                
          each, and (C) we must decide whether the daughters are liable for           
          the additions to tax determined against them.  If issue (2) is              
          answered affirmatively, then the remaining issues are the same              
          except that we must also determine the amount of gain recognized            
          to the daughters in 1985.  If issue (3) is answered                         
          affirmatively, then (A) gain is recognized to Parker, not the               
          daughters, in 1985 (unless certain admissions of respondent's               
          estop her from now claiming that the Parkers must report such               
          gain), (B) we must determine the amount of gain recognized to               
          Parker in 1985, based on certain arguments made by the Parkers,             
          (C) we must determine whether Martha is an innocent spouse,                 
          relieved of liability pursuant to section 6013(e), and (D) we               
          must determine whether Parker is (or the Parkers are) subject to            
          the additions to tax determined by respondent.                              
                                  FINDINGS OF FACT                                    
          Stipulations                                                                
               The parties have entered into the following stipulations of            
          facts that have been filed by the Court:                                    

          2    For simplicity, in describing the various possible gifts, we           
          have ignored the community property interest of Betty Parker                
          (Betty) in the property in question.  Betty was Parker's wife               
          from sometime in 1958 until their divorce in 1982.  Because it is           
          not significant to our analysis, we will continue to ignore                 
          Betty's community property interest in such property.                       




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