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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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