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Accordingly, the taxable estate is decreased $1,090.00.
(f) On the controlling valuation date the fair market value
of the real property identified at Item 6 of Schedule A was
$23,520, rather than $17,520.00 as reported.
Accordingly, the taxable estate is increased $5,750.00.
(g) On the controlling valuation date the fair market value
of the real property identified at Item 7 of Schedule A was
$16,000, rather than $10,260.00 as reported.
Accordingly, the taxable estate is increased $5,740.00.
(h) When the decedent died she was the sole heir of her
predeceased spouse, James R. Rickman, who died on October
19, 1990. On August 8, 1990, James R. Rickman transferred
$20,000.00 to Janet and James O. Tipton by a check which
indicated that such funds were a loan on a home. It is
determined that this note was part of the estate of James R.
Rickman which passed to the decedent and that the such loan
is included in her gross estate.
Accordingly, the taxable estate is increased $20,000.00.
(i) When the decedent died she was the sole heir of her
predeceased spouse, James R. Rickman, who died on October
19, 1990. On August 17, 1990, James R. Rickman directed the
First Union National Bank of North Carolina to transfer two
U.S. Treasury Notes totalling $300,000 to Kaye Rickman,
Janet Tipton and James Tipton. James R. Rickman died before
the bank transferred the Treasury Notes to the designated
donees. Therefore, the Treasury Notes were part of the
estate of James R. Rickman which passed to the decedent and
the value of the Treasury Notes are included in her gross
estate.
Accordingly, the taxable estate is increased
$300,000.00.
The parties agree that exhibits A and B referred to in paragraph
(a) of the explanation of adjustments were not attached to the
notice of deficiency that was sent to petitioner. Respondent
also concedes that there are two errors in the second sentence of
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