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years. Respondent’s 1998 Federal gift tax module account for
petitioner W. August Hillenbrand indicates that there were three
“subsequent payments” made on February 16, 1999, of $26,531,
$187,957, and $71,035. Similarly, respondent’s 1998 Federal gift
tax module account for petitioner Nancy K. Hillenbrand indicates
that there were three “subsequent payments” made on February 16,
1999, of $24,466, $180,949, and $70,718.
In their petition, petitioners contested respondent’s
determinations in the notices of deficiency relating to the GRAT
issues. Respondent’s determinations adjusted the valuation of
the GRATs under section 2702. Respondent and petitioners
conceded that the substantive issue regarding the GRAT issues
would be decided by a case before this Court, Cook v.
Commissioner, 115 T.C. 15 (2000), affd. 269 F.3d 854 (7th Cir.
2001), which was subsequently decided in favor of the
Commissioner. Accordingly, petitioners concede that respondent’s
determined deficiencies, as stated in the notices of deficiency
issued on December 30, 1998, reflect the correct deficiencies in
the instant case.
On May 31, 1999, respondent erroneously refunded $287,827
to petitioner W. August Hillenbrand, consisting of a $285,523
refund and $2,304 in interest. Similarly, on June 7, 1999,
respondent erroneously refunded $278,788 to petitioner Nancy K.
Hillenbrand, consisting of a refund of $276,133 and $2,655 in
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Last modified: May 25, 2011