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GETTY v. COMMISSIONER

Docket No. 18726-85.

91 T.C. 160 (1988)

JEAN RONALD GETTY AND KARIN GETTY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 27, 1988.

Attorney(s) appearing for the Case

Philip S. Magaram and Mark S. Levin, for the petitioners.

Charles W. Jeglikowski and John O. Kent, for the respondent.

COHEN, Judge:

Respondent determined a deficiency of $6,883,975 in petitioners' Federal income tax for 1980. After concessions, the issues for decision are (1) whether petitioner Jean Ronald Getty's receipt of $10 million in settlement of his claim against the residuary beneficiary of his father's estate was exempt from taxation as a gift, bequest, devise, or inheritance, and, if not, (2) whether petitioner Jean Ronald...

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