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ESTATE OF SIMPSON v. COMMISSIONER

Docket Nos. 16581-91, 16582-91.

67 T.C.M. 2938 (1994)

T.C. Memo. 1994-207

Estate of Star C. Simpson, Deceased, Mark O. Simpson, Executor v. Commissioner. Estate of M.O. Simpson, Deceased, Edna J. Sullivan Simpson, Personal Representative v. Commissioner.

United States Tax Court.

Filed May 11, 1994.

Attorney(s) appearing for the Case

Charles A. Pulaski, Jr., Timothy D. Brown, and Janet E. Barton, for the petitioners. Stephen J. McFarlane, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

In these consolidated cases, respondent determined: (1) That on June 12, 1973, Star C. Simpson and her husband, M.O. Simpson, made taxable gifts to their son, Melvin O. Simpson, Jr., and (2) that as a result of such gifts there is due from each parent for the calendar quarter ending June 30, 1973, a deficiency in Federal gift tax in the amount of $331,298, as well as an addition to tax under section...

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