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ESTATE OF KITE v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 6772-08, 6773-08.

T.C. Memo. 2013-43

ESTATE OF VIRGINIA V. KITE, DONOR, DECEASED, BANK OF OKLAHOMA, N.A., EXECUTOR/TRUSTEE, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. ESTATE OF VIRGINIA V. KITE, DECEASED, BANK OF OKLAHOMA, N.A., EXECUTOR/TRUSTEE, Petitioner. v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed February 7, 2013.

Attorney(s) appearing for the Case

John N. Hermes , Dee A. Replogle, Jr. , and Spencer W. Haines , for petitioner.

Ann L. Darnold , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

PARIS, Judge:

In these consolidated cases, respondent issued two notices of deficiency, taking alternative positions with respect to a private annuity transaction. In the notice of deficiency for docket No. 6772-08, respondent determined a $6,053,752 deficiency in the 2001 Federal gift tax of Virginia Vose Kite (Mrs. Kite). In the notice of deficiency for docket No. 6773-08, respondent determined...

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