Estate of Doris L. Rickman, Deceased, Doris K. Rickman, Executrix - Page 4

                                        - 4 -                                         

          The Schedule A of Form 709 filed on behalf of decedent lists                
          the following gifts:                                                        
          Donee               Date                Value                               
          1. Doris K. Rickman      3/22/90             $10,000                        
                                                                                     
          2. Janet R. Tipton       3/22/90             $10,000                        
          Lines 12 through 18 of the Form 709 filed on behalf of decedent             
          indicate that gifts made by decedent during the taxable period              
          would be split with Mr. Rickman.  Line 18 of the Form 709 is                
          signed "Kaye Rickman, Executrix".                                           
          During July 1991, Doris K. Rickman filed separate Forms 706                 
          (United States Estate Tax Return) on behalf of both the Estate of           
          James R. Rickman and petitioner.  Schedule A of Form 706 filed on           
          behalf of the Estate of James R. Rickman lists 7 parcels of real            
          estate included in the gross estate as follows:                             
          Description                      Value at date of death                     
          1 LOT AND BRICK HOME                         $59,500                        
          86 GOLFVIEW DRIVE; FRANKLIN, N.C.                                           
          VALUE BASED ON APPRAISAL, COPY                                              
          WHICH IS ATTACHED                                                           
          1 LOT AND BRICK HOME                         $135,500                       
          92 GOLFVIEW DRIVE; FRANKLIN, N.C.                                           
          VALUE BASED ON APPRAISAL, COPY                                              
          WHICH IS ATTACHED                                                           
          1 LOT AND BRICK HOME                         $47,000                        
          96 GOLFVIEW DRIVE; FRANKLIN, N.C.                                           

          3(...continued)                                                             
          under examination.  In contrast, petitioner contends that the               
          letters serve as an instruction to send the return back to the              
          return preparer.                                                            




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