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SHEPHERD v. COMMISSIONER

Docket No. 2574-97.

115 T.C. 376 (2000)

J.C. SHEPHERD, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 26, 2000.

Attorney(s) appearing for the Case

David D. Aughtry, James M. Kane, and Howard W. Neiswender, for petitioner.

Robert W. West, for respondent.

THORNTON, Judge:

Respondent determined a $168,577 deficiency in petitioner's Federal gift tax for calendar year 1991. The issues for decision are: (1) The characterization, for gift tax purposes, of petitioner's transfers of certain real estate and stock into a family partnership of which petitioner is 50-percent owner and his two sons are each 25-percent owners; (2) the fair market value of the transferred real estate...

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