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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.
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