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SALTZMAN v. C.I.R.

Nos. 217, 910, Docket 96-4195, 96-4203.

131 F.3d 87 (1997)

Eric F. SALTZMAN and Victoria M. Saltzman, Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant. Arnold SALTZMAN and Joan Saltzman, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided December 11, 1997.

Attorney(s) appearing for the Case

Robert W. Metzler, Tax Division, Department of Justice, Washington, DC (Loretta C. Argrett, Assistant Attorney General, Richard Farber, Department of Justice, Washington, DC, on the brief), for Respondent-Appellee.

Kenneth W. Gideon, Washington, DC (Ruth E. Kent, Wilmer, Cutler & Pickering, Washington, DC, of counsel), for Petitioners-Appellants.

Before: VAN GRAAFEILAND, McLAUGHLIN, Circuit Judges, and COTE, District Judge.

VAN GRAAFEILAND, Circuit Judge:

Arnold Saltzman and Joan Saltzman, his wife, appeal from a decision of the United States Tax Court finding them liable for a gift tax deficiency of $978,960 and imposing negligence penalties totalling $575,953.1 For the reasons hereafter discussed, we reverse and remand.

The record in this case fills 10 large packing boxes. Much of it has been ordered sealed. For purposes of this opinion, we see...

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