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On the first, second, and third transfer dates, the
property's adjusted basis was $69,500, $67,906, and $67,108,
respectively. At the time of the first transfer, the fair market
value of the property was $600,000. At the time of the second
and third transfers, the fair market value of the property was
$470,000. The corporation, however, did not possess a plan to
liquidate, sell, or distribute the property in conjunction with
the stock transfers.
On or about October 16, 1992, April 16, 1993, and April 12,
1994, respondent received petitioner's timely filed Federal gift
tax returns, Form 709, for the taxable years 1991, 1992, and
1993, respectively. Respondent issued a statutory notice of
deficiency to petitioner on July, 18, 1995.
On August 12 and September 9, 1996, respondent and
petitioner, respectively, filed motions for summary judgment with
this Court.2
2Subsequently, on Oct. 18, 1996, petitioner amended her
petition in this matter. Petitioner stated that the inclusion of
certain taxes is necessary for the computation of the unified
credit utilized by petitioner with respect to her Forms 709 for
the years at issue. Specifically, petitioner sought to
incorporate, in this matter, certain taxes imposed by the State
of New York, to decrease the value of the corporate stock. On
Dec. 12, 1996, respondent filed an answer to petitioner's
amendment to her petition. In light of our disposition of this
case, we do not address this issue.
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