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gifts for the calendar year 1980 of $64,789, for 1981 of $66,524,
and for 1982 of $2,223,958.
Neither party has explained to the Court the reason for the
differences.
The major issue remaining for decision in both the estate
tax case and the gift tax case is the value of the stock of SOAI
transferred on January 25, 1982. The parties have stipulated
that this value will also be the value in 1980 and 1981, except
for petitioner's contention that market and minority discounts
are applicable to these years. The following issues remain for
decision in the gift tax case: (1) Whether petitioner is liable
for gift taxes with respect to transfers of stock made by
decedent, or his revocable trust, to his son and grandchildren in
December 1980, December 1981, and January 1982; (2) whether the
purported redemption on January 25, 1982, of stock of SOAI held
by decedent's revocable trust was, in part, a gift to decedent's
son; (3) the value of stock in SOAI on January 25, 1982; (4)
whether annual gift tax exclusions are available with respect to
decedent's transfers of stock in SOAI in 1980, 1981, and 1982 to
his daughter-in-law and grandchildren; (5) whether petitioner is
liable for an addition to tax under section 6651(a)(1) for
decedent's failure to file a gift tax return for 1982; and (6)
whether petitioner is liable for an addition to tax under section
6653(a)(1) and (2) for 1982 for negligence or intentional
disregard of rules and regulations.
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