- 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 commonPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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