T.C. Memo. 2001-263
UNITED STATES TAX COURT
ESTATE OF ELMA MIDDLETON DAILEY, DECEASED, DONOR,
K. ROBERT DAILEY, II, EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
ESTATE OF ELMA MIDDLETON DAILEY, DECEASED,
K. ROBERT DAILEY, II, EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 6251-00, 6262-00. Filed October 3, 2001.
Harold A. Chamberlain and Michael C. Riddle, for
petitioners.
Richard T. Cummings, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notices dated March 15, 2000, respondent
determined a 1992 Federal gift tax deficiency of $53,808 and
section 6651(a) addition to tax of $13,452 relating to docket No.
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