Mark W. Senda and Michele Senda v. Commissioner of Internal Revenue

BENTON, Circuit Judge.

Mark W. Senda and his wife, Michele Senda, received a notice from the Commissioner of Internal Revenue for deficiencies in gift tax. Reviewing their petition, the tax court 1 found deficiencies of $185,572 for 1998 and $276,321 for 1999. See Senda v. Comm’r, 2004 WL 1551275 (T.C. Memo. 2004-160) (U.S.Tax Ct.,2004). The Sendas appeal under Section 7482 of the Internal Revenue Code. This court affirms.

I

In the spring of 1998, the Sendas created the Mark W. Senda Family Limited Partnership. Mark Senda — as trustee of his revocable living trust — was the general partner with…