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acquiring any interest in either the Lake Catherine property or
the promissory note.
Accordingly, we sustain respondent’s determination on this
issue.
Other Taxable Gifts
In the notice of deficiency, respondent determined, without
explanation, that decedent made unreported taxable gifts of
$20,000 and $10,000 in 1989 and 1993, respectively. On brief,
respondent contends, with only slightly more specificity, that
this determination is predicated on certain of decedent’s gifts
of C&L Bailey stock to Roger, Frances, and Lillian.
Petitioner concedes that decedent made gifts of C&L Bailey
stock to Roger, Frances, and Lillian but contends they each
received no more than two shares of C&L Bailey stock in any given
year. The parties have stipulated that from 1989 through 1993,
C&L Bailey redeemed 100 of its shares for $5,000 per share.
Therefore, petitioner concludes, each share of stock that
decedent gave away had a value of $5,000, so that his total
annual gift to each donee was $10,000-–an amount equal to the
annual exclusion. Thus, petitioner concludes, decedent’s gifts
of C&L Bailey stock properly were not reported as taxable gifts.
Although petitioner’s assumption of a $5,000 value for the
stock shares in question seems questionable, respondent does not
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