Ripley v. Commissioner
United States Tax Court
In 1983 the donor made gifts of parcels of real estate valued at $ 93,300 to Ps, husband and wife, as tenants in common. During the same year the donor made gifts of other parcels of real estate to a different donee. Controversy arose between the donor and R as to the valuation of the gifts to the other donee.
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In 1983 the donor made gifts of parcels of real estate valued at $ 93,300 to Ps, husband and wife, as tenants in common. During the same year the donor made gifts of other parcels of real estate to a different donee. Controversy arose between the donor and R as to the valuation of the gifts to the other donee. As a result of the donor's timely consents, the 3-year period of limitations for assessment, sec. 6501(a), I.R.C., was extended to Apr. 18, 1990. On Feb. 9, 1990 -- 68 days prior to expiration of the extended period -- R sent the donor a notice of gift tax deficiency. On Feb. 25, 1992,…
1Opinion of the Court
WALTER R. RIPLEY, DONEE-TRANSFEREE OF MILDRED M. RIPLEY, DONOR, AND MELYNDA H. RIPLEY, DONEE-TRANSFEREE OF MILDRED M. RIPLEY, DONOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Ripley v. Commissioner
Docket No. 26209-93.
United States Tax Court
105 T.C. 358; 1995 U.S. Tax Ct. LEXIS 59; 105 T.C. No. 23; 335 T.C.M. (CCH) 17319;
November 8, 1995, Filed
Decision will be entered for respondent.
In 1983 the donor made gifts of parcels of real estate valued at $ 93,300 to Ps, husband and wife, as tenants in common. During the same year the donor made gifts of other parcels of real estate to…
2Cases cited22 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- Robinette v. HelveringSupreme Court of the United States · 1943
- Diedrich v. CommissionerSupreme Court of the United States · 1982
- Moore v. CommissionerUnited States Tax Court · 1942
- McClamma v. CommissionerUnited States Tax Court · 1981
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