3 Decedent was married to Edward Greco (Edward or decedent's spouse) sometime before 1974. They had two sons, Edward F. and Frederick, prior to Edward's death on June 19, 1989. On January 27, 1974, Fleetwood Corp., owned by Edward, Edward F., and Frederick, transferred certain real property located at 1300 Old Chain Ridge Road, McLean, Virginia (real property), to Edward, Edward F., and Frederick, each of whom received a one-third interest as tenant in common. By deed dated April 18, 1974, Edward, Edward F., and Frederick established tenancies by the entireties as between each of them and their respective wives, retaining the tenancy in common as between each couple. The wives of each of the three owners joined in the deed as transferors to convey their dower interests. Decedent had four grandchildren by her two sons. On October 31, 1986, Edward and decedent transferred their one-third interest in the real property to Edward F. and Frederick for life, with the remainder interest to the four grandchildren (designated by name in the deed). On April 15, 1987, Edward and decedent each filed a gift tax return reporting the transfer. On those returns they elected to treat each gift made to their children (and grandchildren) as having been made one-half by each of them, pursuant to section 2513, or a value of $71,372.50 by each, before exemptions. Respondent apparently agrees with this valuation. No gift tax liability then resulted from the transfers.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011