Estate of Doris L. Rickman, Deceased, Doris K. Rickman, Executrix - Page 3

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          Donee               Date                Amount                              
          1. Doris K. Rickman      1/1/90              $10,000                        
          10/16/90            227,583                                                 
          2. Janet R. Tipton       10/16/90            207,583                        
          10/16/90             16,255                                                 
          3. James O. Tipton       10/16/90             20,000                        
          Janet R. Tipton and James O. Tipton are identified as decedent              
          and Mr. Rickman's daughter and son-in-law, respectively.                    
               Form 709, lines 12 through 18, permit a taxpayer to elect to           
          split gifts with his or her spouse as prescribed under section              
          2513; i.e., to have gifts made by the taxpayer and his spouse to            
          third parties during the calendar year considered as made one-              
          half by each.  Lines 12 through 17 of the Form 709 filed on                 
          behalf of Mr. Rickman indicate that gifts made by Mr. Rickman               
          during the taxable period would be split with decedent.  In                 
          particular, decedent is identified by name and Social Security              
          number, and it is acknowledged that Mr. Rickman was married to              
          decedent during the taxable period, and that a gift tax return              
          will be filed by decedent for the same period.  However, line 18,           
          which provides space for decedent's signature signifying her                
          consent to the gift-splitting election, was not signed on                   
          decedent's behalf.  The only marks on line 18 are the handwritten           
          letters "SRB".3                                                             

          3  Although the parties agree that the letters "SRB" were                   
          entered by one of respondent's examiners, they disagree as to               
          their meaning.  Respondent contends that the letters signify that           
          the spouse's return is in the same batch of returns as the return           
                                                             (continued...)           




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Last modified: May 25, 2011