T.C. Memo. 2004-160
UNITED STATES TAX COURT
MARK W. SENDA AND MICHELE SENDA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17298-02. Filed July 12, 2004.
Daniel V. Conlisk, James R. Dankenbring, and James Robert
Loranger, for petitioners.
Thomas C. Pliske, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined deficiencies of
$185,572, $276,321, and $25,674 in petitioners’ Federal gift
taxes for 1998, 1999, and 2000, respectively.
After concessions by respondent, the issue for decision is
whether petitioners’ transfers of stock to two family limited
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