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AUTIN v. COMMISSIONER

Docket No. 4704-92.

102 T.C. 760 (1994)

CLAUDE J. AUTIN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 14, 1994.

Attorney(s) appearing for the Case

E.M. Quijano and Timothy W. Burgmeier, for petitioner.

Stevens E. Moore, for respondent.

WELLS, Judge:

Respondent determined a deficiency in petitioner's Federal gift tax in the amount of $1,649,736 and an addition to tax under section 6651(a)(1) of $412,434. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

The issues for decision are: (1) Whether the...

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