- 3 -
who resided in Englewood, Colorado, when he petitioned the Court,
did not file Federal gift tax returns for the periods under
consideration.
Petitioner is a professional petroleum engineer. In 1955,
he started a consulting practice in petroleum and geophysical
engineering called Jack Grynberg & Associates (JGA). Four years
later, he married Celeste Grynberg (Mrs. Grynberg); they have
three children. Shortly after their marriage, Mrs. Grynberg
contributed $10,000 and several stocks to the business, which
petitioner used to convert the consulting firm to an independent
oil and gas operation, doing business as JGA. From 1959 through
at least the periods in issue, the Grynbergs did not file Forms
1065, U.S. Partnership Return of Income, or have a written
partnership agreement.
The couple began acquiring Federal mineral leases in 1959,
mainly by participating in a lottery conducted by the Bureau of
Land Management of the U.S. Department of the Interior. Under
this system, the Federal Government leased the mineral rights of
its lands in a public drawing. Each person wishing to obtain a
lease had to complete an application form and pay a filing fee;
no person, however, could lease more than 246,080 acres of
Federal land in each State, except Alaska. Although each
applicant was limited to one application per lease, spouses could
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011