June Cordes, et al. - Page 20




                                       - 20 -                                         
               E.  The Gift Tax Returns and Notices of Deficiency                     
               None of the stock transfers at issue in the gift tax cases             
          were made for any consideration.19                                          
               Mr. Cordes timely filed Form 709, United States Gift (and              
          Generation-Skipping Transfer) Tax Return (gift tax return), for             
          1991 but never filed a gift tax return for 1983, 1992, or 1993.             
          In his 1991 gift tax return, Mr. Cordes elected to split gifts              
          with Mrs. Cordes, and Mr. Cordes reported making two gifts--200             
          shares of stock in John Cordes, Inc.,20 and $100,000 cash--both             
          to John Cordes.  Respondent determined, as set forth in his                 
          notice of deficiency, that, pursuant to section 2503(a), Mr.                
          Cordes made taxable gifts in 1983, 1991, 1992, and 1993 of stock            
          and/or cash equivalents.  The following transfers are still at              
          issue:                                                                      






               19In their petitions in docket No. 19256-97 and docket No.             
          19277-97, John Cordes and Jean Ann Richard contend they received            
          items in exchange for their shares equal in value to those shares           
          transferred.  Neither John Cordes nor Jean Ann Richard discussed            
          these contentions at trial or on brief, and the record contains             
          no evidence to support these contentions.  We therefore disregard           
          the statements made in those petitions and find the transfers               
          were made for no consideration.                                             
               20As detailed above, in 1991, Mr. Cordes transferred 300               
          shares of stock in John Cordes, Inc., to John Cordes.  The                  
          parties have stipulated that it is the transfer of 300 shares               
          that is disputed herein.                                                    





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