Peter S. Peracchio - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               HALPERN, Judge:  By notice of deficiency dated May 25, 2001            
          (the notice of deficiency), respondent determined a deficiency in           
          Federal gift tax for calendar year 1997 with respect to                     
          petitioner in the amount of $328,317.  Petitioner timely filed a            
          petition for redetermination.  The dispute involves the value of            
          interests in a family limited partnership transferred by                    
          petitioner to a family trust.                                               
               Unless otherwise noted, all section references are to the              
          Internal Revenue Code in effect on the date of the transfers, 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.  At the time he filed the petition, petitioner              
          resided in Grosse Pointe Woods, Michigan.                                   
          Formation of the Trust and the Partnership                                  
               On November 25, 1997 (the valuation date), petitioner, as              
          settlor, and petitioner’s wife, as trustee, executed a trust                
          agreement creating the Peracchio Family Trust (the trust).  On              
          the same day, petitioner, the trust, and petitioner’s son, John             
          R. Peracchio, executed an agreement of limited partnership (the             
          partnership agreement) with respect to Peracchio Investors, L.P.,           




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