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KNIGHT v. COMMISSIONER

Docket Nos. 11955-98, 12032-98.

115 T.C. 506 (2000)

INA F. KNIGHT, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. HERBERT D. KNIGHT, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 30, 2000.

Attorney(s) appearing for the Case

William R. Cousins III, Robyn A. Frohlin, Todd Allen Kraft, Robert M. Bolton, Robert Don Collier, and John E. Banks, Jr., for petitioners.

Deborah H. Delgado, Gerald Brantley, and James G. MacDonald, for respondent.

COLVIN, Judge:

In separate notices of deficiency sent to each petitioner, respondent determined that each petitioner has a gift tax deficiency of $120,866 for 1994.

Petitioners formed a family limited partnership called the Herbert D. Knight Limited Partnership (the partnership), and gave interests in it to trusts they established for their children. After concessions, the issues for decision are:

...

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