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CULLMAN v. COMMISSIONER

Docket No. 491-80.

42 T.C.M. 1691 (1981)

T.C. Memo. 1981-666

W. Arthur Cullman and Cecilia S. Cullman v. Commissioner.

United States Tax Court.

Filed November 17, 1981.

Attorney(s) appearing for the Case

Sol Morton Isaac and Elbert R. Nester, 100 East Broad St., Columbus, Ohio, for the petitioners. Eugene P. Bogner, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in gift tax due from petitioners for the calendar quarter ending December 31, 1976, as follows:

      Petitioner               Deficiency

  Cecilia S. Cullman ........... $13,594
  W. Arthur Cullman ............  10,875

The only issue for decision is the value on December 29, 1976, of the gifts made by Mrs. Cullman by transferring real property...

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