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DIEDRICH v. COMMISSIONER

Docket No. 1800-77.

39 T.C.M. 433 (1979)

T.C. Memo. 1979-441

Victor P. Diedrich and Frances T. Diedrich v. Commissioner.

United States Tax Court.

Filed November 6, 1979.

Attorney(s) appearing for the Case

Phillip H. Martin and Bruce J. Shnider, 2300 First Nat'l Bank Bldg., Minneapolis, Minn. for the petitioners. Burns Mossman, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined a deficiency of $27,831 in petitioners' 1972 Federal income tax. After concessions, the sole issue for decision is whether petitioners realized income on transfers of stock to or for the benefit of their children where the transfers were conditioned on the donees agreeing to pay Federal and state gift taxes resulting from the transfers.

Findings of Fact

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