FROH v. COMMISSIONER

Docket No. 23022-90.

100 T.C. 1 (1993)

CHARLES T. FROH, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 7, 1993.


Attorney(s) appearing for the Case

Jennifer Miller Moss, for petitioner.

Kathryn K. Vetter, for respondent.


TANNENWALD, Judge:

Respondent determined a deficiency of $175,658 in petitioner's gift tax for 1985. By amendment to answer, respondent asserted an increased deficiency of $483,418. The sole issue herein is the proper method for determining the value of the income interests in three short-term trusts established by petitioner.

FINDINGS OF FACT

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

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