- 22 -
Taxable Year Date of Transfer Details of Transfer
1987 Jan. 7, 1987 100 shares of John
Cordes, Inc., to John
Cordes
1987 Jan. 7, 1987 600 shares of Eddie
Cordes, Inc., to Mr.
Cordes
1988 July 25, 1988 400 shares of Eddie
Cordes, Inc., to Eddy Ben
Cordes
Eddy Ben Cordes never filed a gift tax return for 1983.
Respondent determined, as set forth in his notice of deficiency,
that, pursuant to section 2503(a), Eddy Ben Cordes made a taxable
gift in 1983 to Mrs. Cordes of 334 shares of stock in CFC.
Mrs. Cordes timely filed her 1991 gift tax return but never
filed a gift tax return for 1987, 1993, or 1994. In her 1991
gift tax return, Mrs. Cordes elected to split gifts with Mr.
Cordes, and she reported making a gift to Jean Ann Richard of
1,000 shares of stock in Edmund Cordes, Inc. Respondent
determined, as set forth in his notice of deficiency, that Mrs.
Cordes made taxable gifts of stock and/or cash equivalents in
1987, 1991, 1993, and 1994.22 The following transfers are still
at issue:
22Regarding 1987, respondent determined only that Mrs.
Cordes made taxable gifts; respondent did not determine any
deficiency in Mrs. Cordes’s tax for 1987.
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