Eric F. Saltzman and Victoria M. Saltzman v. Commissioner of Internal Revenue, Arnold Saltzman and Joan Saltzman v. Commissioner of Internal Revenue

VAN GRAAFEILAND, Circuit Judge:

Arnold Saltzman and Joan Saltzman, his wife, appeal from a decision of the United States Tax Court finding them liable for a gift tax deficiency of $978,960 and imposing negligence penalties totalling $575,953. 1 For the reasons hereafter discussed, we reverse and remand.

The record in this case fills 10 large packing boxes. Much of it has been ordered sealed. For purposes of this opinion, we see no reason to take the reader through the entire record, separating sealed from unsealed as we do so. "We limit our discussion to two basic issues:

I. Did the Tax Court…