Estate of Suzanne W. Cullison, Deceased, J. Greg Cullison, Personal Representative - Page 12

                                       - 12 -                                         

               On August 29, 1989, Janet's husband executed a Consent of              
          Spouse, pursuant to which he agreed to abide by the terms of the            
          partnership agreement.                                                      
               On August 30, 1989, decedent's grandchildren by warranty               
          deed conveyed to their Cullison Enterprises partnership the land            
          decedent had transferred to them.  This warranty deed, which had            
          been executed by them on August 30, 1989, was recorded by them on           
          September 8, 1989.                                                          
               From late 1988 until August 29, 1989, decedent continued to            
          be the land's sole owner.  Decedent was entitled to the rents               
          payable by tenants for their use of the land until that date, and           
          she was also liable for any real property taxes imposed covering            
          the period of her ownership up until that date.                             
               From September 1, 1990, through January 19, 1992, decedent's           
          grandchildren never made any of the annual payments they owed to            
          decedent pursuant to the annuity agreement.                                 
               Decedent died on January 19, 1992, when she was 84 years and           
          2 months old.  Neither decedent nor petitioner ever filed any               
          Federal gift tax returns.                                                   
               During the examination of petitioner's estate tax return,              
          the Internal Revenue Service (IRS) estate tax examiner asked Mr.            
          Shadle (who was petitioner's attorney) to obtain and provide him            
          with an appraisal report concerning the value of the land                   
          decedent had transferred to her grandchildren.  As a result, Mr.            





Page:  Previous  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  Next

Last modified: May 25, 2011