STEINBERG v. COMMISSIONER

Docket No. 23865-11.

145 T.C. 184 (2015)

JEAN STEINBERG, DONOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 16, 2015.


Attorney(s) appearing for the Case

John W. Porter , Michael S. Arlein , Keri D. Brown , and Jeffrey D. Watters, Jr. , for petitioner.

John Richard Mikalchus and Molly H. Donohue , for respondent.


Respondent issued petitioner a notice of deficiency, increasing petitioner's gift tax liability by $1,804,908 for tax year 2007. Respondent disallowed the discount petitioner made for her daughters' assumption of the section 2035(b) estate tax liability.

Unless otherwise indicated, all section references are to the Internal...

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