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MATTER OF McLEAN v. NEW YORK STATE TAX COMM'N

86 A.D.2d 730 (1982)

In the Matter of Malcolm P. McLean et al., Petitioners, v. New York State Tax Commission, Respondent

Appellate Division of the Supreme Court of the State of New York, Third Department.

January 28, 1982

Petitioners are husband and wife who seek a redetermination, pursuant to section 689 of the Tax Law, of a deficiency assessed on gifts made in two quarters of 1972. Petitioner Malcolm McLean, on each of two dates, made a gift of 20,000 shares of R.J. Reynolds Industries, Inc. (Reynolds) convertible preferred capital stock in trust for the benefit of a child. Petitioners elected to split the gifts, reporting them as though one half had been made by each. The miscellaneous...

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