- 3 - Respondent examined petitioners’ 1993, 1994, 1995, and 19961 Federal gift tax returns. For the same periods, respondent also examined the gift tax returns of petitioners’ children and son- in-law. Petitioners’ gifts to their children and son-in-law were of Hillenbrand Industries stock, interests in a limited partnership, and remainder interests in certain so-called GRATs. On September 15, 1998, petitioners’ attorney, Larry J. Stroble, sent respondent a letter accompanied by six checks remitted by petitioners, William A. Hillenbrand II, Theresa A. Hartmann, Katherine K. Crowther, Richard D. Hillenbrand II, and Martha L. Tuveson. The letter, dated September 15, 1998, accompanying the six checks, stated: Enclosed are various checks which are to be considered deposits in the nature of cash bonds in accordance with Rev. Proc. 84-58. The checks are cash bonds related to the tax deficiency and interest asserted by the Internal Revenue Service in connection with gift tax examinations of the taxpayers for the years reflected below, and are intended to halt the accrual of interest on such tax deficiencies and previously accrued interest. The six checks totaled $1,457,460. The check remitted on behalf of petitioners was in the amount of $1,242,082, or $621,041 on behalf of each petitioner. Petitioners intended the check to cover their 1993, 1994, 1995, and 1996 Federal gift tax years, as explained in the letter accompanying the check. 1Petitioners’ 1996 Federal gift tax year is not before this Court in the instant case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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