EFTA Document EFTA01459107

Court relied on the price of the shares determined in the Final Decree. In regards to any penalties for not declaring a gift, participants from the firm that provided accounting services for Sumner and NAI some 40 plus years ago, testified about uncertain memories and vague discussions with now deceased partners. A key memory, however, was the fact that one of the accountants recalled that a now deceased senior partner had told Sumner that there was no need to file a gift tax return because