Larry L. Sather, Donor, et al. - Page 3




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                                                 Accuracy-related penalty             
     Donor               Year        Deficiency                sec. 6662(a)           
                                                                                     
     Larry L. Sather1993           $9,915              $1,983                         
     (Larry)                                                                          
     Sandra Sather       1993      22,184              4,437                          
     (Sandra)                                                                         
     John R. Sather      1993      9,678               1,936                          
     (John)                                                                           
     Kathy J. Sather1993           22,160              4,432                          
     (Kathy)                                                                          
     Duane K. Sather     1993      9,679               1,936                          
     (Duane)                                                                          
     Diane R. Sather1993           22,170              4,434                          
     (Diane)                                                                          
               Before trial, respondent conceded the deficiencies and                 
          accuracy-related penalties as to petitioners Duane and Diane due            
          to expiration of the period of limitations.                                 
          Respondent also determined the following trusts were liable as              
          transferees for unpaid gift tax and penalties relating to gifts             
          made by the following donors:                                               
                                                  Accuracy-related penalty            
     Transferee          Donor     Year     Deficiency         sec. 6662(a)           
     Duane K. Sather                                                                  
     Irrevocable Trust      Diane    1992       $22,190             $4,438            
     (Duane Trust)                                                                    
     Larry L. Sather                                                                  
     Irrevocable Trust      Kathy    1992        22,190              4,438            
     (Larry Trust)                                                                    
     John R. Sather                                                                   
     Irrevocable Trust      Sandra   1992        22,190              4,438            
     (John Trust)                                                                     
          After concessions by the parties, we decide the following issues:           
               1.  Whether certain gifts of stock in 1992 and 1993 by                 
          Larry, Kathy, John, Sandra, and Diane in trust for the benefit of           
          their respective nieces and nephews were, in substance, gifts by            
          each of them to his or her own children.  We hold they were.                






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