-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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011