W. August Hillenbrand and Nancy K. Hillenbrand - Page 2




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          issue have been paid, where, in response to the notices of                  
          deficiency, petitioners sent the Internal Revenue Service                   
          remittances and directed that the remittances be applied to the             
          deficiencies in issue, and, subsequently, respondent made an                
          erroneous nonrebate refund of those remittances to petitioners.             
          All section references are to the Internal Revenue Code, as                 
          amended, and all Rule references are to the Tax Court Rules of              
          Practice and Procedure.                                                     
                                     Background                                       
               The parties submitted the instant case fully stipulated,               
          without trial, pursuant to Rule 122.  The parties’ stipulations             
          of facts are hereby incorporated in this opinion by this                    
          reference and are found as facts in the instant case.                       
               Petitioners W. August Hillenbrand and Nancy K. Hillenbrand             
          are husband and wife.  When the petition was filed, they were               
          residents of Batesville, Indiana.  During the years in issue,               
          petitioner W. August Hillenbrand was the chief executive officer            
          of Hillenbrand Industries, Inc.                                             
               During 1993, 1994, and 1995, petitioners made substantial              
          gifts to their children and son-in-law.  In 1993, 1994, and 1995,           
          petitioners also made contributions to trusts commonly referred             
          to as “Grantor Retained Annuity Trusts” (GRATs).  Petitioners               
          each filed Federal gift tax returns for 1993, 1994, and 1995.               








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