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ESTATE OF METZGER v. COMMISSIONER

Docket No. 4952-91.

100 T.C. 204 (1993)

ESTATE OF ALBERT F. METZGER, DECEASED, JOHN A. METZGER AND Z. TOWNSEND PARKS, JR., PERSONAL REPRESENTATIVES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 23, 1993.

Attorney(s) appearing for the Case

Luther B. Ditch, for petitioner.

Clare J. Brooks, for respondent.

HAMBLEN, Chief Judge:

Respondent determined a deficiency of $11,701 in the Federal estate tax of the Estate of Albert F. Metzger (petitioner).1 This case is presently before the Court on cross-motions for partial summary judgment pursuant to Rule 121.

After concessions, the sole remaining issue for decision is whether Albert F. Metzger made taxable gifts of $20,000 during his lifetime. Central to this issue is the question...

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