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Because we find that Mrs. Winkler did not make
taxable gifts of interests in the winning Lotto ticket,
there is no estate tax deficiency, and we need not address
petitioners' alternative contention that the Estate of
Emerson Winkler is entitled to an increased marital
deduction. Based upon our finding that there are no tax
deficiencies in this case, we hold that petitioners are not
liable for the penalties under section 6662(a) that were
determined by respondent in the subject notices of
deficiency.
Decision will be entered
for petitioners.
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