- 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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