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JANDA v. COMMISSIONER

Docket Nos. 5100-99, 5101-99.

81 T.C.M. 1100 (2001)

T.C. Memo. 2001-24

Donald J. Janda v. Commissioner. Dorothy M. Janda v. Commissioner.

United States Tax Court.

Filed February 2, 2001.

Attorney(s) appearing for the Case

Larry A. Holle and Terry R. Wittler, for the petitioners.

Henry N. Carriger, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

In these consolidated cases, respondent determined separate gift tax deficiencies of $73,323 against petitioners Donald J. Janda (Mr. Janda) and Dorothy M. Janda (Mrs. Janda) for 1992. The issue for decision is the fair market value of the shares of stock in the St. Edward Management Co. (the Company) transferred by each petitioner to their children.

Section references are to the Internal Revenue...

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