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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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