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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners resided in Santa Barbara, California, at the
time the petitions were filed.
During all years relevant to the transactions at issue,
petitioners operated an agricultural business known as Thornhill
Ranches on property of the same name that was owned by petitioner
and located in southern California. During those years, peti-
tioners, operating as Thornhill Ranches, employed their two sons
Stephen Miller (Stephen) and Robert N. Miller IV (Robert) to
assist them in managing the business and determined the salaries
and bonuses that they received.6 During those same years, peti-
tioners also owned and operated a commercial property business
located in Georgia that their son Robert helped manage.
Throughout the period 1982 through 1985, petitioner retained
the accounting firm of Pannell, Kerr, and Forster (PKF) to
maintain her financial records and to prepare her Federal gift
5(...continued)
contend, that the transfer to Robert N. Miller IV was made in
1983 rather than 1982. We therefore accept the parties' agree-
ment that petitioner made the $100,000 transfer to Robert N.
Miller IV in 1982.
6 Stephen and his wife filed joint Federal income tax returns
for the years 1982 through 1985 in which they reported gross
income, including wages and salaries, that ranged from approxi-
mately $64,000 to $73,000. Robert filed individual Federal
income tax returns for the years 1982, 1984, and 1985 in which he
reported gross income, including wages and salaries, that ranged
from approximately $79,000 to $90,000.
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