June Cordes, et al. - Page 55

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                                        the annual exclusions are                     
                                        applicable.                                   
               B.   1992:                                                             
                    1.   Respondent determined petitioner made a taxable              
                         gift of $31,000 to John Cordes in 1992.                      
                         Petitioner, in his petition, alleged that the                
                         transfer of $31,000 was a loan, rather than a                
                         taxable gift.  Petitioner introduced no evidence             
                         of a loan and did not present any argument                   
                         regarding this adjustment in his posttrial briefs.           
                         We deem petitioner to have conceded the transfer             
                         of $31,000 to John Cordes was a taxable gift.                
                    2.   Respondent determined petitioner made a taxable              
                         gift of $20,000 to John Cordes in 1992.                      
                         Petitioner has not presented any argument                    
                         regarding this adjustment in his petition or                 
                         posttrial briefs.  We deem petitioner to have                
                         conceded that the transfer is a taxable gift, as             
                         defined in sec. 2503(a).                                     
                    3.   Respondent determined petitioner was liable for an           
                         addition to tax for 1992, pursuant to sec.                   
                         6651(a)(1), for failure to file a gift tax return.           
                         Petitioner concedes he did not file a gift tax               
                         return for 1992 and did not present any argument             
                         regarding the addition to tax.  We deem petitioner           
                         to have conceded liability for the addition to               
                         tax.                                                         
               C.   1993:                                                             
                    1.   Respondent determined petitioner made a taxable              
                         gift of $10,000 to John Cordes in 1993.                      
                         Petitioner, in his petition, alleged that the                
                         transfer of $10,000 was a loan, rather than a                
                         taxable gift.  Petitioner introduced no evidence             
                         of a loan and did not present any argument                   
                         regarding this adjustment in his posttrial briefs.           
                         We deem petitioner to have conceded the transfer             
                         of $10,000 to John Cordes was a taxable gift.                
                    2.   Respondent determined petitioner made a taxable              
                         gift of $30,000 to John Cordes in 1993.                      
                         Petitioner has not presented any argument                    
                         regarding this adjustment in his petition or                 
                         posttrial briefs.  We deem petitioner to have                
                         conceded that the transfer is a taxable gift, as             
                         defined in sec. 2503(a).                                     
                    3.   Respondent determined petitioner was liable for an           
                         addition to tax for 1993, pursuant to sec.                   
                         6651(a)(1), for failure to file a gift tax return.           
                         Petitioner concedes he did not file a gift tax               

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