T.C. Memo. 1998-216
UNITED STATES TAX COURT
ESTATE OF SUZANNE W. CULLISON, DECEASED, J. GREG CULLISON,
PERSONAL REPRESENTATIVE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11573-96. Filed June 17, 1998.
James Powers, for petitioner.
Rick V. Hosler, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge: Respondent determined a deficiency in Federal
gift tax against petitioner for 1989 of $559,435 and a deficiency
in Federal estate tax of $506,298.
After concessions, the issues for decision are:
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