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WEEDEN v. COMMISSIONER

Docket No. 4815-75.

39 T.C.M. 699 (1979)

T.C. Memo. 1979-498

Estate of Norman D. Weeden, Deceased, William F. Weeden, Executor v. Commissioner.

United States Tax Court.

Filed December 12, 1979.

Attorney(s) appearing for the Case

John M. Hammerman, Robert M. Winokur, Leland H. Faust, One California St., San Francisco, Calif., for the petitioner. Gerald J. Beaudoin, for the respondent.

Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined a $23,240 deficiency in decedent's 1969 income tax. The issue for decision is whether decedent realized gain upon the gift of stock to his nephews when the gift was conditioned on the nephews' paying the resulting gift tax liability.

Findings of Fact

Substantially all the facts have been stipulated and are found accordingly.

Norman D. Weeden ("decedent")...

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