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ESTATE OF ROBINSON v. COMMISSIONER

Docket Nos. 14599-90, 939-91.

101 T.C. 499 (1993)

ESTATE OF INEZ T. ROBINSON, DECEASED, TOM ED ROBINSON AND RALPH E. ROBINSON, CO-EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 2, 1993.

Attorney(s) appearing for the Case

Robert H. Hishon, for petitioner.

Eric B. Jorgensen and Lawrence B. Austin, for respondent.

WELLS, Judge:

Respondent determined a deficiency in the Federal gift tax of Inez T. Robinson (decedent) in the amount of $717,252 for taxable year 1983. In addition, respondent determined a deficiency in decedent's estate's (petitioner's) Federal estate tax in the amount of $276,411. Petitioner filed separate petitions with respect to the gift tax deficiency and the estate tax deficiency. The instant cases have been consolidated for purposes of trial, briefing...

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