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BALLARD v. COMMISSIONER

Docket No. 37108-85.

53 T.C.M. 323 (1987)

T.C. Memo. 1987-128

Eleanor M. Ballard v. Commissioner.

United States Tax Court.

Filed March 10, 1987.

Attorney(s) appearing for the Case

Lawrence A. Jegen III, Indiana University, Indianapolis, Ind., for the petitioner. Russell D. Pinkerton, for the respondent.

Memorandum Opinion

PARKER, Judge:

Respondent determined a deficiency in petitioner's gift tax for the calendar quarter ended June 30, 1981, in the amount of $87,618.17, and a section 6651(a)(1)1 addition to the tax in the amount of $13,142.73. The issues for decision are:

(1) Whether petitioner may use the interest rates published in the regulations under section 483 to value an intra-family installment sale for gift...

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