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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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