- 17 -
Respondent further determined that the decedent's total
amount of taxable gifts as of the end of 1990 amounted to
$2,491,175, of which the gifts made in connection with the
recapitalization are the principal component.
Among other adjustments made in the notice of estate
tax deficiency issued to the decedent's estate, respondent
determined that the adjusted taxable gifts reported on the
decedent's estate tax return, $527,217, should be increased
to reflect the gifts determined in the notice of gift tax
deficiency, including the gifts made to the decedent's two
sons in connection with the recapitalization. The notice
of deficiency describes this adjustment in the following
terms:
The amount of $527,217.00 shown on the
estate tax return as adjusted taxable gifts
is increased $1,963,958.00 as a result of the
increase in the amount of adjusted taxable gifts
made by the decedent during the years in 1988,
1989 and 1990. Accordingly, it is determined
that the amount of adjusted taxable gifts added
to the taxable estate is $2,491,175.00.
OPINION
In the gift and estate tax returns that are the
subject of these consolidated cases, the decedent's estate
took the position that no gifts were made by the decedent
when he exchanged voting common stock for nonvoting common
Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: May 25, 2011