June Cordes, et al. - Page 21




                                       - 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.                                            





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