Estate of Davenport v. Commissioner

McKAY, Circuit Judge.

Petitioner-Appellant, the Estate of Bir-nie M. Davenport as represented by Patricia L. Vestal, appeals from a decision of the United States Tax Court finding the Estate liable for a federal gift tax deficiency in the amount of $822,653.00 and a penalty in the amount of $205,663.00. This dispute involves a gift tax deficiency notice for the third quarter of 1980 issued by the Commissioner of Internal Revenue with respect to three alleged inter vivos gifts of stock in Hondo Drilling Company, Inc. The Tax Court determined that, during the third quarter of 1980, the decedent,…