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ESTATE OF SCHULER v. COMMISSIONER

Docket No. 14002-99.

80 T.C.M. 934 (2000)

T.C. Memo. 2000-392

Estate of Robert V. Schuler, Deceased, Jay Schuler & Thomas Schuler, Co-Personal Representatives v. Commissioner.

United States Tax Court.

Filed December 28, 2000.

Attorney(s) appearing for the Case

Richard E.T. Smith, Jon J. Jensen, and Gary A. Pearson, for the petitioner. Tracy Anagnost Martinez and Melissa J. Hedtke, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

PARR, Judge:

Respondent determined a deficiency of $215,758 in the Federal estate tax due from the estate of Robert V. Schuler (decedent).

After concessions,1 the sole issue for decision is whether decedent's transfers of stock in 1994 and 1995 to members of his brother's family were, in substance, indirect gifts of stock to members of his own family. We hold they were.

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