Christine M. Hackl - Page 2




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               Barton T. Sprunger and Mark J. Richards, for petitioners.              
               Russell D. Pinkerton, for respondent.                                  


                                       OPINION                                        

               NIMS, Judge:  By separate statutory notices, respondent                
          determined a deficiency in the 1996 Federal gift tax liability of           
          petitioner Christine M. Hackl (Christine Hackl) in the amount of            
          $309,866 and in the 1996 Federal gift tax liability of Albert J.            
          Hackl, Sr. (A.J. Hackl), in the amount of $309,950.  Petitioners            
          each timely filed for redetermination by this Court, and, due to            
          an identity of issues, the cases were consolidated for purposes             
          of trial, briefing, and opinion.  In accordance with stipulations           
          of partial settlement filed by the parties, the sole matter                 
          remaining for decision is whether gifts made by petitioners of              
          units in a limited liability company qualify for the annual                 
          exclusion provided by section 2503(b).                                      
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect for the year at             
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
                                     Background                                       
               These cases were submitted fully stipulated pursuant to Rule           
          122, and the facts stipulated are so found (except as noted in              
          footnote 1).  The stipulations of the parties, with accompanying            





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