O'Neal v. Commissioner
United States Tax Court
On Nov. 3, 1987, Gs gave their grandchildren, Ps, stock in A. Gs around Apr. 15, 1988, filed separate United States Gift (and Generation-Skipping Transfer) Tax Returns for 1987, reporting the gifts of the stock, and paid the amount of gift tax shown on the returns.
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On Nov. 3, 1987, Gs gave their grandchildren, Ps, stock in A. Gs around Apr. 15, 1988, filed separate United States Gift (and Generation-Skipping Transfer) Tax Returns for 1987, reporting the gifts of the stock, and paid the amount of gift tax shown on the returns. Prior to Apr. 15, 1991, when the 3-year period of limitations under sec. 6501(a), I.R.C., expired as to Gs' gift tax for 1987, R never requested an extension of time for asserting a deficiency in gift tax and generation-skipping transfer tax against Gs or asserted such a deficiency. On Apr. 13, 1992, R sent to each P two notices of…
1Opinion of the Court
OPINION
Scott, Judge:
Pursuant to Rule 121,2 this matter is before the Court on respondent’s motion for partial summary judgment (respondent’s motion) and petitioners’ cross-motion for summary judgment (petitioners’ motion), filed September 8, 1993, and September 27, 1993, respectively. On October 18, 1993, petitioners filed a second motion for summary judgment (petitioners’ second motion).
Respondent determined that petitioners are liable as donees/transferees of Kirkman O’Neal in 1987 for gift taxes of $7,040,223, for generation-skipping transfer taxes of $197,651, and for additions to tax…
2Cases cited25 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Associated Press v. United StatesSupreme Court of the United States · 1945
- Commissioner v. SternSupreme Court of the United States · 1958
- Espinoza v. CommissionerUnited States Tax Court · 1982
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3Cited by21 opinions
- Bresson v. CommissionerUnited States Tax Court · 1998
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- Hawkins v. Comm'rUnited States Tax Court · 2003
- United States v. Estate of DavenportDistrict Court, N.D. Oklahoma · 2001
- Webb v. CommissionerUnited States Tax Court · 1996
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