Chambers v. Commissioner
United States Tax Court
The majority of CEI's voting and nonvoting common stock was held by three trusts, the Atlanta Trust I, the Atlanta Trust II, and the Dayton Trust. In December 1975, petitioner Anne Cox Chambers held a percentage interest in the life estate of the Atlanta Trust I of which petitioner Barbara Cox Anthony was the trustee, and petitioner Barbara Cox Anthony held a percentage interest in the life estate of the Atlanta Trust II of which petitioner Anne Cox Chambers was the trustee.
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The majority of CEI's voting and nonvoting common stock was held by three trusts, the Atlanta Trust I, the Atlanta Trust II, and the Dayton Trust. In December 1975, petitioner Anne Cox Chambers held a percentage interest in the life estate of the Atlanta Trust I of which petitioner Barbara Cox Anthony was the trustee, and petitioner Barbara Cox Anthony held a percentage interest in the life estate of the Atlanta Trust II of which petitioner Anne Cox Chambers was the trustee. Both petitioners held a percentage interest in the life estate of the Dayton Trust and were two of the three…
1Opinion of the Court
OPINION
STERRETT, Chief Judge:
These consolidated cases are before the Court on petitioners’ motion for summary judgment filed pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
In his statutory notices of deficiency dated February 3, 1983, respondent determined deficiencies in petitioners’ Federal gift taxes as follows:
Docket No. Petitioner Calendar year ended Dec. 31— Deficiency
10188-83 Robert W. Chambers 1976 $25,247.33
10189-83 Garner Anthony 1976 11,130.34
10190-83 Barbara Cox Anthony 1976 10,319.96
1977 82.25
1978 27.931.65
1979 28,719.90
10191-83 Anne Cox Chambers 1976 25,247.33
197…
2Cases cited13 opinions
- Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
- Welch v. HelveringSupreme Court of the United States · 1933
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Merrill v. FahsSupreme Court of the United States · 1945
- United States v. ByrumSupreme Court of the United States · 1972
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3Cited by5 opinions
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- Chambers v. CommissionerUnited States Tax Court · 1986