Bergeron v. Commissioner

KATHERINE BERGERON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bergeron v. Commissioner

Docket No. 36850-85.

United States Tax Court

T.C. Memo 1986-587; 1986 Tax Ct. Memo LEXIS 18; 52 T.C.M. (CCH) 1177; T.C.M. (RIA) 86587;

December 17, 1986.

Lee E. Wall, for the petitioner.

Ellen T. Friberg, for the respondent.

COHEN

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge: By notice of deficiency dated July 25, 1985, respondent determined deficiencies in and additions to petitioner's Federal gift tax as follows:

Quarter

Additions to Tax

Ending

Deficiency

Sec. 6651(a)(1) 1

Sec. 6653(a)

June 30,…