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Check No. 4408, for $180,949, is marked “1993 Nancy K.
Hillenbrand”. Check No. 4409, for $24,466, is marked “1994 Nancy
K. Hillenbrand”. Check No. 4410, for $70,718, is marked “1995
Nancy K. Hillenbrand”. All checks were drawn on the same account
at Bank One, Indianapolis, N.A. (the foregoing six checks are
collectively hereinafter sometimes referred to as the February
12, 1999, remittances).
Respondent did not post the February 12, 1999, remittances
to the years designated by petitioners; i.e., petitioners’ 1993,
1994, and 1995 Federal gift tax years. Rather, in error,
respondent posted the February 12, 1999, remittances to
petitioners’ 1998 Federal gift tax year, as reflected on
respondent’s accounts for petitioners’ 1998 Federal gift taxes
(respondent refers to these accounts as module accounts, and
hereinafter those accounts will be referred to as module
accounts). Respondent never issued a notice of deficiency for
petitioners’ 1998 Federal gift tax year, and there is no
indication in the record that petitioners were liable for any
Federal gift taxes for 1998 or that such liabilities were ever
contemplated by either party.
Respondent’s internally generated module accounts for
petitioners’ 1998 Federal gift tax year were consistent in
amounts with the February 12, 1999, remittances that were
designated for petitioners’ 1993, 1994, and 1995 Federal gift tax
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Last modified: May 25, 2011