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PERACCHIO v. COMMISSIONER

Docket No. 10470-01.

86 T.C.M. 412 (2003)

T.C. Memo. 2003-280

Peter S. Peracchio v. Commissioner.

United States Tax Court.

Filed September 25, 2003.

Attorney(s) appearing for the Case

Eric M. Nemeth, Michael J. Mulcahy, and Brian C. Bernhardt, for the petitioner.

John W. Stevens, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN, Judge:

By notice of deficiency dated May 25, 2001 (the notice of deficiency), respondent determined a deficiency in Federal gift tax for calendar year 1997 with respect to petitioner in the amount of $328,317. Petitioner timely filed a petition for redetermination. The dispute involves the value of interests in a family limited partnership transferred by petitioner to a family trust.

Unless otherwise...

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