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MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: These cases have been consolidated for
trial, briefing, and opinion. By notices of deficiency dated
December 16, 1996, respondent determined deficiencies in Federal
gift taxes as follows:
Docket
Number Petitioner Year Deficiency
1460-97 Walter L. Gross, Jr. 1992 $584,139
1460-97 Barbara H. Gross 1992 584,140
1469-97 Calvin C. Linnemann 1992 581,605
1469-97 Patricia G. Linnemann 1992 582,807
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The common question presented by these consolidated cases is
the July 31, 1992, fair market value of certain shares of
corporate stock transferred by gift by petitioners Walter L.
Gross, Jr. (Walter Gross), and Patricia G. Linnemann (Patricia
Linnemann) to their respective children. Petitioners Barbara H.
Gross (Barbara Gross) and Calvin C. Linnemann (Calvin Linnemann),
the wife and husband of Walter Gross and Patricia Linnemann,
respectively, are petitioners because they and their respective
spouses consented to having the gifts made by each spouse
considered for Federal gift tax purposes as having been made
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