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OWEN v. COMMISSIONER

Docket No. 8960-75.

37 T.C.M. 272 (1978)

T.C. Memo. 1978-51

Ralph Owen and wife, Lulu H. Owen v. Commissioner.

United States Tax Court.

Filed February 6, 1978.

Attorney(s) appearing for the Case

William Waller, Lawrence Dortch, and Justin P. Wilson, 12th Floor, American Trust, Nashville, Tenn., for the petitioners. John B. Harper, for the respondent.

Memorandum Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $502,266.83 in petitioners' joint Federal income tax for 1973. The issue for decision is whether petitioners realized net income as a result of certain transactions in which they transferred highly appreciated securities to trusts for the benefit of their grandchildren, upon the condition that the recipient trusts would pay the gift taxes resulting from the transfers...

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