Estate of Anne F. Greco, Deceased, Frederick D. Greco, Co-Administrator - Page 4

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               Edward died on June 19, 1989, less than 3 years after the              
          transfer on October 31, 1986.  The estate tax return for his                
          estate reported adjusted taxable gifts of $51,372.50, which is              
          $71,372.50 less two $10,000 exclusions pursuant to section                  
          2503(b), representing the life estates created in Edward F. and             
          Frederick.                                                                  
               Petitioner did not include the gift of real property made by           
          decedent on October 31, 1986, as an adjusted taxable gift on                
          decedent's estate tax return.  In the notice of deficiency,                 
          respondent determined that the estate must include $51,372.50 as            
          adjusted taxable gifts, and that there were no further exclusions           
          available for the grandchildren, as those interests were merely             
          future interests.                                                           
               A tax is imposed upon the transfer of the taxable estate of            
          a decedent who is a citizen or resident of the United States.               
          Sec. 2001(a).  The tax is computed first by determining a                   
          tentative tax on the sum of the taxable estate and the adjusted             
          taxable gifts, and then reducing that tentative tax by the amount           
          of gift tax that would have been payable on those gifts, using              
          the rates in effect at the decedent's death.  Sec. 2001(b).  The            
          term "adjusted taxable gifts" for purposes of this subsection               
          means all taxable gifts made by decedent after December 31, 1976,           
          other than gifts that are includable in the gross estate of                 
          decedent.  Taxable gifts are the total amount of gifts made                 
          during the calendar year, less any available deductions or                  




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