Irene Eisenberg - Page 4

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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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