T.C. Memo. 2006-225
UNITED STATES TAX COURT
ESTATE OF MARGOT STEWART, DECEASED, BRANDON STEWART, EXECUTOR,
Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
ESTATE OF MARGOT STEWART, DECEASED, DONOR, BRANDON STEWART,
EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 5520-05, 5521-05. Filed October 24, 2006.
Kirk H. O’Ferrall, Kathleen M. Citera, and Robert Callagy
(specially recognized), for petitioners.
Shawna A. Early and Lydia A. Branche, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: The issues for decision are whether decedent
made a completed gift of a 49-percent interest in real property,
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