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ESTATE OF KOLKER v. COMMISSIONER

Docket No. 17058-80.

80 T.C. 1082 (1983)

ESTATE OF MIRIAM R. KOLKER, DECEASED, FABIAN H. KOLKER AND GLORIA K. HACK, PERSONAL REPRESENTATIVES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 25, 1983.

Attorney(s) appearing for the Case

Charles M. Cahn, Jr., and Michael J. Kandel, for the petitioner.

Daniel J. Wiles, for the respondent.

OPINION

TIETJENS, Judge:

Respondent determined a deficiency of $9,821.82 in petitioner's Federal gift tax. The issue for our determination is whether a transfer to a trust on December 29, 1976, by Miriam R. Kolker was a gift of a present interest, capable of valuation and qualifying for the exclusion provided by section 2503(b).1

This case was fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and...

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