-4- The Court decides the motion for litigation and administrative costs based upon the pleadings, petitioner's motion with attached exhibits, respondent's response with attached exhibits, petitioner's reply to respondent's response with attached exhibits, the parties' stipulations, and petitioner's additional affidavit. The relevant facts as drawn from the record are set out below. Background Petitioner and Mr. Thompson resided at Milledgeville, Georgia, at the time the petition in this case was filed. Mr. Thompson is the chief executive of and principal shareholder in T & S Hardwoods, Inc. (the Company). The Company is a closely held family corporation located in Milledgeville, Georgia. The Company is engaged in the operation of hardwood sawmills. On August 8, 1988, Mr. Thompson made gifts of stock in the Company to his son and two daughters.5 On April 18, 1989, the Internal Revenue Service received a Form 709, United States Gift and Generation-Skipping Transfer Tax Return, signed by L. N. Thompson, Jr., as donor. Petitioner also signed the return indicating her consent to "split-gift" treatment under section 5Petitioner and Mr. Thompson had given "split gifts" of stock in the Company to their children in the years 1986 and 1987 that reduced the amount of unified credit available for application to the tax on the gifts made in 1988. See sec. 2505(a). This issue has been settled by agreement of the parties.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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