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COTTRELL v. COMMISSIONER

Docket No. 1816-77.

72 T.C. 489 (1979)

LOIS P. COTTRELL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 13, 1979.

Attorney(s) appearing for the Case

John W. Windhorst, Phillip H. Martin, and Kenneth L. Cutler, for the petitioner.

Robert F. Cunningham, for the respondent.

WILES, Judge:

Respondent determined a $4,639,402.50 deficiency and a $231,970.13 addition to tax under section 6653(a)1 in petitioner's 1970 Federal gift tax. The two issues are whether petitioner made a taxable gift under section 2511 when she executed a disclaimer of her remainder interest in her father's testamentary trust and whether she is subject to an addition to tax under section...

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