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return for 1993 and did not present any argument
regarding the addition to tax. We deem petitioner
to have conceded liability for the addition to
tax.
II. Docket No. 19279-97, June Cordes:
A. 1993:
1. Respondent determined petitioner made taxable
gifts to John Cordes in 1993, in the aggregate
amount of $76,900. Petitioner, in her petition,
alleged that the transfers are not taxable gifts
only because the applications of the unified
credit and annual exclusions, see sec. 2503,
reduce her tax liability. Petitioner has not
presented any argument regarding these adjustments
in her posttrial briefs. We deem petitioner to
have conceded that the transfers are taxable
gifts, as defined in sec. 2503(a), subject to the
annual exclusion in 2503(b). We leave for the
Rule 155 computation whether and to what extent
the unified credit and the annual exclusions are
applicable.
2. 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 she did not file a gift tax
return for 1993 and did not present any argument
regarding the addition to tax. We deem petitioner
to have conceded liability for the addition to
tax.
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