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Cordes’s purchases of the Bower Note and the Richard Note for
amounts less than their fair market values.
III. The Gift Tax Cases
In the gift tax cases, respondent determined that members of
the Cordes family transferred shares among themselves without
properly reporting those transfers or paying gift tax thereon.
Below, we set forth the findings of fact specifically relevant to
the gift tax cases. The details of the stock transfers can be
found in Appendix A, Schedule of Stock Transfers.13
A. CFC Stock Transfers
CFC initially issued 500 shares of stock in January 1964--
250 shares to Mr. Cordes, 249 shares to Mrs. Cordes, and 1 share
to B.B. Journeycake (Mrs. Cordes’s father). On January 4, 1965,
B.B. Journeycake transferred 1 share to the Eddy Ben Cordes
Trust. On January 8, 1965, Mrs. Cordes transferred 28 shares to
Eddy Ben Cordes. On December 29, 1965, Mr. Cordes transferred 50
shares, Mrs. Cordes transferred 50 shares, and the Eddy Ben
Cordes Trust transferred 1 share, to Eddy Ben Cordes. On
December 16, 1966, Mr. Cordes transferred 100 shares to Eddy Ben
Cordes. On January 8, 1971, CFC issued 500 additional shares of
13The record does not contain complete information regarding
all of the stock transfers which took place before and during the
taxable years at issue. As the stock transfers pertain to the
issues in the gift tax cases, however, the record contains
information sufficient for us to decide the issues presented by
these cases.
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