- 21 -
Taxable Year Date of Transfer Details of Transfer
1983 Mar. 29, 1983 600 shares of Eddie
Cordes, Inc., to Jean Ann
Richard
1991 Aug. 8, 1991 600 shares of Eddie
Cordes, Inc., to Eddy Ben
Cordes
1991 Aug. 8, 1991 300 shares of John
Cordes, Inc., to John
Cordes
John Cordes never filed a gift tax return for 1994.
Respondent determined, as set forth in his notice of deficiency,
that, pursuant to section 2503(a), John Cordes made a taxable
gift in 1994 to Mr. Cordes of 500 shares of stock in John Cordes,
Inc.21
Jean Ann Richard never filed a gift tax return for 1987 or
1988. Respondent determined, as set forth in his notice of
deficiency, that, pursuant to section 2503(a), Jean Ann Richard
made the following taxable gifts:
21Respondent subsequently took the position in Cordes v.
Commissioner, T.C. Memo. 2002-125, that John Cordes instead sold
these 500 shares to Mr. Cordes for $800,000, and respondent
acknowledged this change in position from that taken in the case
before us. In light of our finding herein regarding the
beneficial ownership of John Cordes, Inc., we decline to address
respondent’s change of position.
Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: May 25, 2011