Estate of Sylvia Gore, Donor, Deceased, Pamela Powell, Personal Representative - Page 2




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          (the estate).1  By separate notice of deficiency, respondent                
          determined a Federal gift tax deficiency of $918,962 with respect           
          to Sylvia Gore’s 1997 taxable year.  The personal representative            
          of the estate filed separate petitions to redetermine the                   
          deficiencies of the estate.  These cases were consolidated for              
          purposes of trial, briefing, and opinion pursuant to Rule 141(a)            
          because they present common questions of fact and law.                      
          Hereinafter, we shall refer to these consolidated cases as this             
          case.                                                                       






















               1All section references are to the Internal Revenue Code               
          (Code) in effect for June 12, 1997, the date of Sylvia Gore’s               
          death, and for the taxable year 1997, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           





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