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.
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