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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.
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