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HALPERN, Judge: By separate notices of deficiency dated
April 13, 2000 (the notices), respondent determined deficiencies
in Federal gift tax for calendar year 1996 with respect to
petitioner Charles McCord, Jr. (Mr. McCord) and petitioner Mary
McCord (Mrs. McCord) in the amounts of $2,053,525 and $2,047,903,
respectively. The dispute centers around the gift tax
consequence of petitioners’ assignments to several charitable and
noncharitable donees of interests in a family limited
partnership.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect on the date of the assignments,
and all Rule references are to the Tax Court Rules of Practice
and Procedure. All dollar amounts have been rounded to the
nearest dollar.
FINDINGS OF FACT
Some facts are stipulated and are so found. The stipulation
of facts, with accompanying exhibits, is incorporated herein by
this reference.
Petitioners
Petitioners are husband and wife. They have four sons, all
adults (the children): Charles III, Michael, Frederick, and
Stephen. In response to the notices, petitioners filed a single
petition. At the time they filed the petition, petitioners
resided in Shreveport, Louisiana.
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