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interest each was acquiring. The monthly statements of
Prudential Bache for the Julian P. Kornfeld Life Estate indicated
the separate receipt of funds from petitioner, Meredith, Nancy,
and Permenter.
Neither Meredith, Nancy, nor Permenter was under any legal
obligation to utilize the funds received from petitioner to
acquire their interests in the purchased bonds. However, they
and petitioner intended that the funds would be so used.
Annexed hereto as Exhibit 1 is a schedule reflecting the
date and amount of each bond purchase involved herein, the
closing date of Prudential Bache, dates of petitioner's gifts3 to
the other parties, and the dates of payments by petitioner and
the other parties.
Petitioner furnished Nancy, Meredith, and Permenter with
funds in rounded amounts equal to the payments they made to
Prudential Bache. Neither Nancy, Meredith, nor Permenter
expended any amount in excess of the funds so furnished to make
any part of such payments.
Petitioner filed gift tax returns reflecting the gifts to
Nancy, Meredith, and Permenter but paid no tax on account of the
unified credit. See sec. 2505. Petitioner reported no other
gifts to Meredith, Nancy, or Permenter during the years at issue.
3 The use of the word "gifts" is not dispositive of the subject
of the gifts by petitioner, i.e., of funds or interests in the
bonds, which is the critical issue herein.
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