June Cordes, et al. - Page 3




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          Collectively, the above five cases are referred to as the income            
          tax cases.                                                                  
               In these consolidated cases, respondent also determined                
          deficiencies in petitioners’ Federal gift tax and additions to              
          tax as follow:                                                              
          Docket No. 19178-97                                                         
          Petitioner Edmund J. Cordes:                                                
                                             Additions to tax                         
                    Year      Deficiency     sec. 6651(a)(1)                          
                    1983      $73,100        $18,275                                  
                    1991      349,503             -0-                                 
                    1992      18,450         4,613                                    
                    1993      13,500         3,375                                    
          Docket No. 19256-97                                                         
          Petitioner John J. Cordes:                                                  
                                             Addition to tax                          
                    Year      Deficiency   sec. 6651(a)(1)                            
                    1994      $154,230       $38,558                                  
          Docket No. 19277-97                                                         
          Petitioner Jean Ann Richard:4                                               
                                             Additions to tax                         
                    Year      Deficiency     sec. 6651(a)(1)                          
                    1987      $16,650        $4,163                                   
                    1988      130,500        32,625                                   






               4The parties and exhibits refer to this petitioner as Jean             
          Ann Cordes and as Jean Ann Richard.  Jean Ann Cordes married                
          Joseph P. Richard prior to the issuance of the notices of                   
          deficiency.  Throughout this opinion, we shall refer to her as              
          Jean Ann Richard or petitioner for the sake of clarity.  Neither            
          her name nor marital status has any bearing on our holdings                 
          herein.                                                                     




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