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ESTATE OF ANDERSON v. COMMISSIONER

Docket No. 21508-87.

56 T.C.M. 553 (1988)

T.C. Memo. 1988-511

Estate of James W. Anderson, Deceased, Richard K. Anderson, Executor v. Commissioner.

United States Tax Court.

Filed October 31, 1988.

Attorney(s) appearing for the Case

Walter H. Bush, Jr., Milford B. Hatcher, Jr., Linda W. Munden and Oliver C. Murray, Jr., 3300 First Atlanta Tower, Atlanta, Ga., for the petitioner. Charles P. Hanfman, for the respondent.

Memorandum Findings of Fact and Opinion

WILLIAMS, Judge:

The Commissioner determined a deficiency in the Federal estate tax due from the Estate of James W. Anderson in the amount of $1,212,527. After concessions, the issue remaining for our decision is whether decedent made a gift to his son in 1982 by contributing common stock of three operating companies to a newly formed holding company in exchange for preferred stock.

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