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After application of the annual exclusions and unified credit,
these adjustments resulted in a total proposed 1996 gift tax
liability of $371,792. Petitioner filed a written protest to the
proposed changes, acknowledging that they pertained to his gift
tax liability for 1996.
Because further correspondence failed to yield any agreement
between petitioner and respondent on the valuation issues, on
March 20, 2000, respondent mailed to petitioner at his last known
address a statutory notice of deficiency. The deficiency notice
indicated that it was for tax year ending December 31, 1995, and
asserted a gift tax deficiency for 1995 in the amount of
$367,623, the same amount stated in the 30-day letter for 1996
that was previously sent to petitioner. Petitioner received the
deficiency notice on March 22, 2000. Attached to the cover page
of the deficiency notice was a Form 4089-c, Notice of
Deficiency--Waiver, a Form 3615-A, Explanation of Tax Changes,
and an additional schedule detailing the revisions to the values
of the transferred partnership interests. The Form 4089-c and
the Form 3615-A both referred to a tax year ending December 31,
1995. The Form 3615-A contained figures corresponding to the
1996 gift tax return filed by petitioner as well as the
examiner’s report for 1996 gift tax. The additional schedule
contained no reference to the taxable period, but it detailed the
gift transactions made by petitioner on December 26, 1996, and
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