Betty W. Thompson - Page 2

                                         -2-                                          
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               DEAN, Special Trial Judge:  This matter is before the Court            
          on petitioner's Motion for Litigation and Administrative Costs              
          pursuant to section 7430 and Rule 231.                                      
               In separate notices of deficiency addressed to Betty W.                
          Thompson (hereinafter petitioner) and her husband, Lawrence N.              
          Thompson (hereinafter Mr. Thompson), respondent determined a                
          deficiency in and an addition to the Federal gift tax liability             
          of each of them as follows:                                                 
               Calendar                           Addition to Tax                     
               Year Ended     Deficiency            Sec. 6660                         
               12/31/88       $398,683.08         $119,605                            
               The adjustment in the respective notices of deficiency was             
          primarily attributable to respondent's determination that the               
          value of gifts of common stock made in the year 1988 was                    
          $3,163,500, instead of $1,260,072 as reported on the gift tax               
          return signed by petitioner and Mr. Thompson.2                              
               The petition in this case was filed on September 1, 1993.              
          On November 5, 1993, the Court issued its notice setting                    
          petitioner's case and Mr. Thompson's case for trial at the                  
          April 11, 1994, trial calendar in Atlanta, Georgia.  Within the             
          period allowed by Rule 143(f), petitioner and Mr. Thompson                  
          submitted an expert witness report on the valuation of the                  

               2The notices also determined that there were taxable gifts             
          from prior periods in the amount of $27,575.33 and not "$0.00" as           
          reported on the return.                                                     





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