T.C. Memo. 2002-145 UNITED STATES TAX COURT LEO J. POLACK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12739-98. Filed June 10, 2002. Barry A. O’Neil and Glenn R. Kessel, for petitioner. Blaine C. Holiday and David Zoss, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: Respondent determined a deficiency of $442,200 in petitioner’s Federal gift tax for the taxable year 1992. After concessions, the sole issue for decision is the valuation of petitioner’s gifts of shares of stock in Zip Sort, Inc., that he made to his children on December 31, 1992.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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