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HULL v. COMMISSIONER

Docket No. 88551.

21 T.C.M. 1076 (1962)

T.C. Memo. 1962-199

Eva B. Hull v. Commissioner.

United States Tax Court.

Filed August 17, 1962.

Attorney(s) appearing for the Case

Ronald M. Mankoff, Esq., Fidelity Union Tower, Dallas, Tex., for the petitioner. Harold D. Rogers, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner has determined a deficiency in gift tax against petitioner for the year 1955 of $20,694.11 and an addition to tax under section 6651(a) of the Internal Revenue Code of 1954 in the amount of $5,173.53. In the deficiency notice the Commissioner stated:

Explanation of Adjustments to Taxable Gifts It is held that 49% of the excess of the value of properties transferred to Hull Enterprises Corporation...

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