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tax return, decedent submitted two checks in payment of the
reported liabilities: For 1991, he submitted a $1,200,341 check
drawn on the trust’s bank account and a $29,142 check drawn on
his personal bank account; for 1992, he submitted a $3,015,595
check drawn on the trust’s bank account and a $11,495 check drawn
on his personal bank account.
Respondent’s Gift Tax Determinations
After decedent’s death in 1993, respondent determined that
decedent’s 1991 and 1992 gifts of National Fruit stock had a
value of $109 per share, rather than $100 per share as reported
on the gift tax returns, resulting in gift tax deficiencies of
$118,801 and $304,910 for 1991 and 1992, respectively. The
estate consented to the immediate assessment and collection of
these determined gift tax deficiencies.
Payment of the 1991 and 1992 Assessed Gift Tax Deficiencies
In December 1995, respondent received payment from the trust
for the 1991 and 1992 assessed gift tax deficiencies and interest
thereon. As of November 20, 1998, none of the donee children had
paid any of decedent’s gift tax liabilities, gift tax
deficiencies, or interest with respect to decedent’s gifts for
any taxable year.
Refund Claims for Gift Taxes Paid
In April 1996, the estate and the trust filed separate,
partially duplicative refund claims with respect to decedent’s
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