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McDONALD v. COMMISSIONER

Docket Nos. 37673-84, 37694-84.

89 T.C. 293 (1987)

GLADYS L. McDONALD, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT ESTATE OF JOHN McDONALD, DECEASED, C.F. CORNELIUS, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 18, 1987.

Attorney(s) appearing for the Case

Garry A. Pearson, for the petitioners.

Gail K. Gibson, for the respondent.

OPINION

GERBER, Judge:

Respondent determined a $90,163.37 Federal gift tax deficiency regarding Gladys L. McDonald for the taxable quarter ended September 30, 1981, and a $152,013.67 estate tax deficiency for the Estate of John McDonald. These cases were submitted fully stipulated pursuant to Rule 122.2 The stipulated facts and attached exhibits are incorporated herein by this reference.

The two issues presented...

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