- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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