Estate of Joseph Cidulka, Deceased, James S. Bozik, Administrator - Page 4

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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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