- 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.
Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: May 25, 2011