Ripley v. Commissioner
United States Tax Court
In 1983 the donor made gifts of parcels of real estate valued at $ 93,300 to Ps, husband and wife, as tenants in common. During the same year the donor made gifts of other parcels of real estate to a different donee. Controversy arose between the donor and R as to the valuation of the gifts to the other donee.
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In 1983 the donor made gifts of parcels of real estate valued at $ 93,300 to Ps, husband and wife, as tenants in common. During the same year the donor made gifts of other parcels of real estate to a different donee. Controversy arose between the donor and R as to the valuation of the gifts to the other donee. As a result of the donor's timely consents, the 3-year period of limitations for assessment, sec. 6501(a), I.R.C., was extended to Apr. 18, 1990. On Feb. 9, 1990 -- 68 days prior to expiration of the extended period -- R sent the donor a notice of gift tax deficiency. On Feb. 25, 1992,…
1Opinion of the Court
OPINION
Raum, Judge:
Respondent issued notices of donee/trans-feree liability to petitioners, each in the amount of $93,300. At issue is: (1) Whether the period of limitations for assessment of transferee liability prescribed by section 6901(c)(1)1 had expired, and (2) the amount of petitioners’ transferee liability under section 6324(b).
The liability at issue results from gifts made by Mildred M. Ripley (donor) in 1983 to her son, petitioner Walter R. Ripley and petitioner Melynda H. Ripley, Walter’s wife. At the time the joint petition in this case was filed, petitioners resided in…
2Cases cited21 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- Robinette v. HelveringSupreme Court of the United States · 1943
- Diedrich v. CommissionerSupreme Court of the United States · 1982
- Moore v. CommissionerUnited States Tax Court · 1942
- McClamma v. CommissionerUnited States Tax Court · 1981
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3Cited by10 opinions
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- Ripley v. CommissionerCourt of Appeals for the Fourth Circuit · 1996
- Depasture v. United States (In Re Depasture)United States Bankruptcy Court, M.D. Georgia · 2009
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