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Petitioners claimed no deduction on account of any claim against
the estate by Bell.
During the years at issue, decedent filed only one gift tax
return. That return was filed in 1975, and reports a gift of
real property to Bell.
Respondent’s Adjustments on Account of Taxable Gifts
Respondent examined the ledgers and determined the Bell
payments for each year. Respondent then subtracted certain
unspecified amounts from each year’s total Bell payments. The
resulting differences are the amounts determined by respondent as
gifts to Bell for each year. The Bell payments treated by
respondent as gifts are as follows:
Year Amount
1964 $6,610
1965 8,093
1966 9,959
1967 13,499
1968 12,190
1969 6,790
1970 6,769
1971 9,449
1972 7,610
1973 8,443
1975 21,812
1976 3,283
1978 3,436
1979 4,273
1981 5,430
1985 82,849
1987 57,789
1988 27,879
1990 32,379
1991 18,119
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