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MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: Respondent determined deficiencies in
Bonnie I. Barge’s Federal gift tax for 1987 and 1988 in the
amounts of $5,547,988 and $4,000, respectively. Respondent also
determined an addition to tax under section 6660 in the amount of
$1,664,396 for 1987. Respondent has since conceded that no
addition to tax under section 6660 is due. We accept that
concession. The only issue remaining for decision is the value
of a 25-percent interest in certain timberland that was the
subject of gifts made by Bonnie I. Barge in 1987. Respondent’s
determination of a deficiency in gift tax liability for 1988 is a
consequence of her determination with respect to 1987, and it
requires no separate analysis from us.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable periods in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulation of facts filed by the parties with accompanying
exhibits is incorporated herein by this reference. Bonnie I.
Barge filed the petition in this case on January 3, 1992. At
that time, she resided in Macon, Mississippi. Subsequently, she
died, and we ordered that Estate of Bonnie I. Barge, C. Richard
Barge, Executor, be substituted as petitioner.
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