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DALLAS v. COMMISSIONER

Docket No. 7493-04.

92 T.C.M. 313 (2006)

T.C. Memo. 2006-212

Robert Dallas v. Commissioner.

United States Tax Court.

September 28, 2006.

Attorney(s) appearing for the Case

John M. Elias, Peter J. Ulrich, Rita M. Danylchuk, and Laura Lavie, for petitioner.

Wendy D. Gardner and Brian E. Derdowski, Jr., for respondent.

John M. Elias, Peter J. Ulrich, Rita M. Danylchuk, and Laura Lavie, for petitioner.*

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Chief Judge:

Respondent determined deficiencies in petitioner's gift tax of $1,715,526 for 1999 and $823,160 for 2000.1

Petitioner transferred about 55 percent of the nonvoting stock of the Dallas Group of America, Inc. (DGA), an S corporation the stock of which is not publicly traded, to trusts established for the benefit of his sons (the trusts) in exchange for cash and...

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