Tracy P. Streber, F.K.A. Tracy C. Parker, et al. - Page 17

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          Teresa received a check for $1,700,000 upon signing and                     
          surrendering her note.                                                      
               At or about the time of the settlement of the lawsuit,                 
          Northgate Forest Development Corp. executed and delivered a                 
          warranty deed conveying two lots in the Northgate Forest                    
          subdivision to Tracy and a second warranty deed conveying another           
          two lots to Teresa.                                                         
          I.  Deficiencies                                                            
               A.  Introduction                                                       
               Respondent has determined inconsistent deficiencies in                 
          income tax against both the Parkers and the daughters.  She asks            
          the Court to determine who, as between the Parkers and the                  
          daughters, is properly taxable with respect to the proceeds of              
          certain notes (the $2 million notes).  There is no question that            
          the proceeds of the $2 million notes ended up in the hands of the           
          daughters, and that that happened as a result of certain gifts              
          made to them by Parker.  We must, however, determine when those             
          gifts occurred.  Put another way, we must determine who, as                 
          between Parker and the daughters, owned the $2 million notes for            
          Federal income tax purposes at the time the notes were paid.                
               The Parkers argue that Parker made gifts to the daughters              
          either (1) before or at the time that the joint venture was                 
          created in 1980 or (2) when the Bradish group interest in the               
          joint venture was sold in 1981, and the $2 million notes were               

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