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— It is the value of Corus stock that the Joseph Glickmans each transferred to the trust four years ago that is at the heart of the dispute. The IRS ruled that the 1.82 million shares they gave to the trust was worth $58 million. The Glickmans claim the actual stock value is just under $242,000. Corus stock is traded on the NASDAQ stock exchange.

The IRS notice of deficiency ruled that as a result of its findings, the value of the Glickmans' taxable gifts for 1994 was being increased by $57.8 million. Joseph and Beverly Glickman were each ordered to pay $16.2 million in gift taxes for that year.

But the petitions filed by the couple challenged the ruling. The petitions claimed that the IRS erred in reaching that decision.

According to a quarterly statement filed June 30 by the bank with the Securities and Exchange Commission, the bank bought back 269,100 shares of its stock at $40.98 a share during the April-June period. The repurchase was part of a Corus program to buy back 750,000 shares of common stock. The report said the bank has 14.5 million shares of outstanding common stock.

Published reports said the Glickman family, which also includes their daughter, Elaine Galinson, San Diego's chief of protocol in 1993, owned more than half the bank's outstanding common stock when the Joseph Glickmans made the transfers to the trust in 1994.

Their daughter and her husband, Murray, an attorney and chairman of the San Diego National Bank, are big contributors to the Democratic Party, pals of former vice president Walter "Fritz" Mondale, and have been known to rub elbows with the Clintons.

Murray Galinson was recommended by Senator Dianne Feinstein and tapped by President Clinton for a federal judgeship in 1995 but dropped out after controversy boiled up over whether he was nominated as payback for the family's financial support of the party.

Campaign reports show the Galinson couple contributed more than $75,000 to Democratic candidates during this decade, including $10,000 they gave to Kathleen Brown's unsuccessful 1994 gubernatorial run.

"Actually, he dropped out," said Kristy Gregg, a spokeswoman for the San Diego National Bank, of Galinson's nomination. "He got tired of what it was doing to his personal life."

At the time of the nomination, Galinson had been away from the courtroom for more than a decade. Galinson began his legal career as a federal prosecutor in Minnesota and later went into private practice in that state. He served as a special federal prosecutor for two years in San Diego.

After the IRS responded July 21 to the Glickman couple's petitions, the case shifted to the IRS Appellate Division, where the two sides entered into negotiations. If the IRS and the couple fail to negotiate a settlement, the case would go to trial before a tax court judge.

The Glickmans have designated Chicago as the site of a trial, if one becomes necessary.

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