Legal Opinion

Brotzler v. Commissioner

United States Tax Court

Decided October 21, 1982No. Docket No. 13010-79Unpublished

Held, under the facts petitioners did not make a completed gift of land to the United States.

1Opinion of the Court

DAVID P. BROTZLER AND ARLISS J. BROTZLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Brotzler v. Commissioner

Docket No. 13010-79.

United States Tax Court

T.C. Memo 1982-615; 1982 Tax Ct. Memo LEXIS 129; 44 T.C.M. (CCH) 1478; T.C.M. (RIA) 82615;

October 21, 1982.

Held, under the facts petitioners did not make a completed gift of land to the United States.

Jerrold M. Hartke, for the petitioners.

Sue A. Nelson, for the respondent.

WHITAKER

MEMORANDUM FINDINGS OF FACT AND OPINION

WHITAKER, Judge: Respondent determined deficiencies in petitioners' income taxes as follows:

Year

Deficiency

1975

$6…

2Cases cited14 opinions

  1. Weil v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1936
  2. Guest v. CommissionerUnited States Tax Court · 1981
  3. Estate of Hite v. CommissionerUnited States Tax Court · 1968
  4. Oehler v. FalstromSupreme Court of Minnesota · 1966
  5. Greer v. CommissionerUnited States Tax Court · 1978

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