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Issue 4. Are Petitioners Liable for Valuation Understatement
Penalties Under Section 6662(a), (g), and (h)? . 320
FINDINGS OF FACT ...................... 320
OPINION ........................... 322
Appendix .......................... 334
Schedule 1 ....................... 334
Schedule 2 ....................... 335
Schedule 3 ....................... 336
BEGHE, Judge: Respondent determined Federal gift and estate
tax deficiencies and accuracy-related penalties under sections
6662(a), (g), and (h)2 in the following amounts:
Docket No. Tax Year Deficiency Penalties
10940-97 Gift 12/31/93 $15,201,984 $6,080,794
3409-98 Estate 06/04/941 43,639,111 17,455,644
3408-98 Gift 12/31/94 17,094,788 6,791,715
Totals 75,935,883 30,328,153
1 Date of death.
Introduction
In each of these consolidated cases, respondent determined a
gift or estate tax deficiency and penalty arising from a gross
valuation understatement. The deficiencies and penalties relate
to valuations of ownership interests in various corporations and
partnerships (collectively, the True companies), subject to buy-
sell agreements, transferred individually in 1993 by H.A. True,
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect as of the date of Dave True’s
death (for estate tax purposes) or dates of Dave and Jean True’s
alleged gifts (for gift tax purposes). All Rule references are
to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011