T.C. Memo. 1996-112
UNITED STATES TAX COURT
JANE O. KOSMAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27091-93. Filed March 11, 1996.
James M. Bausch, Larry A. Holle, and Terry R. Wittler, for
petitioner.
Albert B. Kerkhove, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined that petitioner
Jane O. Kosman has gift tax deficiencies of $158,136 for 1986 and
$15,157 for 1987.
The issue for decision is the fair market value of Kosman,
Inc., stock that petitioner gave to her children on September 30,
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