WALL v. COMMISSIONER

Docket Nos. 1590-98, 1850-98.

81 T.C.M. 1425 (2001)

T.C. Memo. 2001-75

John E. Wall v. Commissioner. Joanne Wall v. Commissioner.

United States Tax Court.

Filed March 27, 2001.


Attorney(s) appearing for the Case

Rex A. Guest and Melvin L. Katten, for the petitioners.

Michael F. O'Donnell and George W. Bezold, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

BEGHE, Judge:

Respondent determined a $73,789 deficiency in petitioner John E. Wall's gift tax for calendar 1992. Respondent also determined a $73,789 deficiency in the 1992 gift tax of Mr. Wall's spouse, petitioner Joanne Wall. Mrs. Wall is a party to these consolidated cases solely because petitioners elected to treat Mrs. Wall as the donor of one-half of the gifts Mr. Wall made during 1992. See sec. 2513.

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