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Decedent died July 27, 1990, 4 months after the codicil was
written. Kenneth Dowell did not inherit anything from decedent's
estate.
Cancellation of the Debt
Decedent was readmitted to the hospital in July of 1990 and
was told she had only a short time to live. Decedent knew her
daughter would have a problem paying for the agency stock. On or
about July 18, 1990, 9 days before her death, decedent asked her
daughter to bring the agreement to her in the hospital. Patricia
Low brought decedent the only thing she had at home, the
amortization schedule, which decedent signed, dated, and marked
"paid in full". Decedent told her daughter that she was
canceling the payments due under the agreement. Decedent did not
say why, and her daughter did not ask for her specific reason.
At the time of the cancellation, Patricia Low had made six
payments under the agreement. The amortization schedule shows
her remaining obligation as $183,520.
Patricia Low's Federal income tax return for the year 1990
does not include any item of income regarding debt cancellation.
Post-Death Events
After decedent died, her daughter went to Jan Seigel and
asked him what she should do as potential executrix. She did the
same with William Grinwis. Patricia Low never asked Jan Seigel
any questions about the payments totaling $450,000 ($3,750 x 12 x
10) that she was to make to her father under the codicil.
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