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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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Last modified: May 25, 2011