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The only remaining issue in the estate tax case is the
amount of prior years' gifts to be included in the amount of the
taxable estate.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly.
The petitioner in these consolidated cases, docket Nos.
22456-91 and 564-93, is the Estate of Joseph Cidulka, deceased,
James S. Bozik, administrator. Mr. Bozik, whose office was
located in Valparaiso, Indiana, was appointed administrator after
the time of the filing of the petitions in these cases. Decedent
was domiciled in Portage, Indiana, at the time of his death. A
U.S. Estate Tax Return, Form 706, was timely filed on behalf of
decedent's estate. A U.S. Quarterly Gift Tax Return, Form 709,
for the calendar quarter ended December 31, 1976, was filed by
decedent and was the only gift tax return ever filed by decedent.
Decedent was predeceased by his wife, Helen Cidulka.
Decedent's son, Mr. John C. Cidulka (John Cidulka or John), was
predeceased by his wife, Charlesa Cidulka. John and Charlesa
Cidulka had two children, John Joseph Cidulka (John Joseph), born
on January 16, 1968, and Lauren Jean Cidulka (Lauren), born on
June 28, 1965. John Cidulka married Marilyn Cidulka following
the death of Charlesa Cidulka.
Decedent was born on February 24, 1904, and died on October
20, 1987. John Cidulka died on November 14, 1993.
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