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additions to tax, and penalties that respondent determined Frank
and Katherine owed for the years in issue. Previously, by letter
dated July 20, 1996, respondent determined that Frank and
Katherine had transferred the following assets to Ronnie upon
which transferee liability attached:
Description Amount
Annual gifts in form of excess of
applications of funds over sources of funds:
1983 $35,946
1984 52,672
1985 30,834
1986 27,525
1987 48,010
1988 64,360
1989 73,937
1990 60,223
Glendale Federal savings account transfer 21,550
Longwood property equity 311,000
One-half interest in St. Lucie County property 4,000
Total assets transferred 730,057
The parties agree that for the years 1983 through 1990,
Ronnie acquired the following assets:
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