DICKERSON v. COMMISSIONER OF INTERNAL REVENUE

No. 20029-08.

T.C. Memo. 2012-60

TONDA LYNN DICKERSON, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 6, 2012.


Attorney(s) appearing for the Case

David M. Wooldridge , Donald Eugene Johnson , Gregory P. Rhodes , and Ronald A. Levitt , for petitioner.

Horace Cump and Edwin B. Cleverdon , for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge.

This case is before the Court on a petition for redetermination of a $771,570 gift tax deficiency for the tax year 1999. There are two issues. First, did petitioner make a taxable gift when she contributed a winning lottery ticket to a newly formed corporation in which she owned only 49% of the stock and other family members owned the rest? Second, if petitioner did make a gift, what was the value of...

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