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reflected in a notice of deficiency issued to petitioner on
January 16, 1992.
Executor later petitioned the Court on December 30, 1993, to
redetermine respondent’s determination with respect to Decedent’s
Federal gift taxes. This determination, which appeared in a
notice of deficiency dated October 27, 1993, was as follows:
Taxable Additions to Tax
Year Sec. Sec.
Ended Deficiency 6651(a) 6653(a)(1)
12/31/76 $169,765 $42,441 ---
3/31/77 48,891 12,223 ---
3/31/79 154,717 38,679 ---
3/31/80 689,139 172,285 ---
3/31/81 144,291 36,073 ---
12/31/82 741,731 185,433 ---
12/31/83 482,500 --- $24,125
12/31/84 178,240 44,560 ---
12/31/85 1,344,795 336,199 ---
12/31/86 142,983 35,746 ---
12/31/87 267,002 66,750 ---
12/31/88 228,353 57,088 ---
Respondent also determined that Decedent was liable for an
addition to her 1983 gift tax under section 6653(a)(2).
The two cases resulting from the petitions were consolidated
on July 28, 1994, for purposes of trial, briefing, and opinion.
On May 12, 1995, the resulting case was settled with the
simultaneous execution of a decision document in the gift tax
case and a stipulation of settled issues (the Stipulation) in the
estate tax case. A decision was entered in the gift tax case on
May 26, 1996, determining deficiencies in Decedent’s gift taxes
1(...continued)
the maximum credit allowable for State death taxes under sec.
2011 is allowed.
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