Estate of Ellie B. Williams, Deceased, Robert M. Driggers, Sr., Personal Representative, et al. - Page 3

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          1983 are $211,000 and $221,000, as petitioners contend; $784,700            
          and $989,662.50, as respondent contends; or some other amounts.             
          We hold that the value of the 1980 gift is $379,960 and the value           
          of the 1983 gift is $486,150.                                               
               3.   Whether petitioner is liable as a transferee for                  
          decedent's gift tax deficiencies for 1980 and 1983.  We hold that           
          he is.                                                                      
               4.   Whether the fair market value of decedent's undivided             
          one-half interest in 843.26 acres of timberland when she died was           
          $143,000, as petitioners contend; $360,500, as respondent                   
          contends; or some other amount.  We hold that the value of the              
          timberland was $177,085.                                                    
               5.   Whether, as respondent contends, the fair market value            
          of a 1992 Cadillac Brougham was $24,500 at the date of decedent's           
          death.  We hold that it was.                                                
               Section references are to the Internal Revenue Code.  Rule             
          references are to the Tax Court Rules of Practice and Procedure.            
                                I.  FINDINGS OF FACT                                  
          A.   Petitioners                                                            
               1.   Ellie B. Williams                                                 
               Ellie B. Williams (decedent) was born in April 1908.  Her              
          husband was Frank Williams (Williams).  They had no children.               
          Williams died on September 4, 1962.  Decedent inherited about               








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