Jack J. Grynberg - Page 2




                                         - 2 -                                           
                   Additions to Tax                                                      

          Quarter Ending       Deficiency      Sec. 6651(a)(1)      Sec.                 
          6653(a)                                                                        
          Mar. 31, 1980        $1,248,737          $312,184            $62,437           
          June 30, 1980           588,884           147,221             29,444           
          Sept. 30, 1980          158,804            39,701              7,940           
          Dec. 31, 1980           296,003            74,001             14,800           
          Mar. 31, 1981           611,271           152,818             30,564           
          Total               2,903,699           725,925            145,185             
               All section references are to the Internal Revenue Code in                
          effect for 1980 and 1981, and all Rule references are to the Tax               
          Court Rules of Practice and Procedure, unless otherwise noted.                 
               After concessions, the Court must decide:  (1) Whether                    
          petitioner gifted coal, uranium, oil, and gas leases (collec-                  
          tively, mineral leases), or overriding royalty interests,1 to his              
          wife; if so, (2) the value of such gifts; and (3) whether peti-                
          tioner is liable for additions to tax for not filing Federal gift              
          tax returns and for negligently or intentionally disregarding the              
          applicable rules and regulations.  Petitioner concedes that he                 
          made completed gifts of overriding royalties to trusts for the                 
          benefit of his children; the parties do not agree, however, on                 
          royalty values for purposes of computing the gift tax.                         
                                    FINDINGS OF FACT                                     
               We incorporate in this opinion the parties’ stipulation of                
          facts, stipulation of settled issues, and exhibits.  Petitioner,               

               1An overriding royalty represents the right to a fraction or              
          percentage of the lessee's share of the minerals removed, as                   
          distinguished from the royalty interest retained by the lessor.                
          See William & Meyers, Manual of Oil and Gas Terms 765 (9th ed.                 
          1994).                                                                         




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