- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011