SCHOTT v. COMMISSIONER

Docket Nos. 469-00, 470-00.

81 T.C.M. 1600 (2001)

T.C. Memo. 2001-110

Patricia A. Schott v. Commissioner. Stephen C. Schott v. Commissioner.

United States Tax Court.

Filed May 9, 2001.


Attorney(s) appearing for the Case

Scott A. Bieber, Chicago, Illinois, for the petitioners.

Catherine M. Thayer, James A. Whitten, and William E. Bogner, for the respondent.


MEMORANDUM OPINION

COHEN, Judge:

Respondent determined Federal gift tax deficiencies for 1994 in Docket No. 469-00 in the amount of $126,080 and in Docket No. 470-00 in the amount of $137,953.

The issue for decision in these consolidated cases is whether a successor annuity interest of a spouse in a retained two-life annuity is a qualified interest that is subject to valuation pursuant to section 2702. Unless otherwise indicated, all section references...

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