- 35 - 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 notPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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