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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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