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WANDRY v. COMMISSIONER OF INTERNAL REVENUE

Nos. 10751-09, 10808-09

T.C. Memo. 2012-88

JOANNE M. WANDRY, DONOR, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. ALBERT D. WANDRY, a.k.a. A. DEAN WANDRY, DONOR, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 26, 2012.

Attorney(s) appearing for the Case

William N. Krems , Steven R. Anderson , and Richard D. D'Estrada , for petitioners.

Patricia A. Komor and Philip E. Blondin , for respondent.

MEMORANDUMS OPINION

HAINES, Judge:

These cases arise from petitions for redetermination filed in response to notices of deficiency (deficiency notices) issued to petitioner Albert Wandry and petitioner Joanne Wandry for 2004. The issues for decision are: (1) whether petitioners transferred gifts of a specified dollar value of membership units or fixed percentage interests in Norseman Capital, LLC, a Colorado limited liability company, to their children and...

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