Estate of Anne F. Greco, Deceased, Frederick D. Greco, Co-Administrator - Page 3

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               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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