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HALLENBECK v. COMMISSIONER

Docket No. 12879-79.

46 T.C.M. 1204 (1983)

T.C. Memo. 1983-523

Eleanor C. Hallenbeck and William W. Hallenbeck v. Commissioner.

United States Tax Court.

Filed August 24, 1983.

Attorney(s) appearing for the Case

Robert A. Bergquist and Charles C. Parlin, Jr., 55 Wall St., New York, N.Y., for the petitioners. Robert J. Shilliday, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined the following deficiencies in petitioners' Federal gift tax:

                    Calendar
  Petitioner    Quarter Ending   Deficiency

Eleanor C.
  Hallenbeck    June 30, 1974    $255,712.96
William W.
  Hallenbeck    June 30, 1974    $255,712.96

The only issue presently before us is whether Eleanor C. Hallenbeck made a taxable gift when she executed...

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