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SENDA v. COMMISSIONER

Docket No. 17298-02.

88 T.C.M. 8 (2004)

T.C. Memo. 2004-160

Mark W. Senda and Michele Senda, v. Commissioner.

United States Tax Court.

July 12, 2004.

Attorney(s) appearing for the Case

Daniel V. Conlisk, James R. Dankenbring, and James Robert Loranger, for petitioners;

Thomas C. Pliske, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

Respondent determined deficiencies of $185,572, $276,321, and $25,674 in petitioners' Federal gift taxes for 1998, 1999, and 2000, respectively.

After concessions by respondent, the issue for decision is whether petitioners' transfers of stock to two family limited partnerships, coupled with petitioners' transfers of limited partnership interests to their children (or in trust therefor), constitute...

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