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WILSON v. COMMISSIONER

Docket No. 10948-90.

64 T.C.M. 583 (1992)

T.C. Memo. 1992-480

Catherine L. Wilson v. Commissioner.

United States Tax Court.

Filed August 24, 1992.

Attorney(s) appearing for the Case

Yale F. Goldberg, Michael W. Murphy, and David R. Frazer, 5353 N. 16th St., Phoenix, Ariz., for the petitioner. Mary P. Kimmel, for the respondent.

Memorandum Findings of Fact and Opinion

RUWE, Judge:

Respondent determined a deficiency of $4,189,821 in petitioner's Federal gift taxes. The sole issue for decision is whether the transfer of certain real estate by petitioner to her children in exchange for their promissory note constitutes a taxable gift for purposes of section 2512.1

Findings of Fact

Some of the facts have been stipulated and are so found...

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