Estate of Anne F. Greco, Deceased, Frederick D. Greco, Co-Administrator - Page 5

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          exclusions.  Sec. 2503.  Thus, lifetime gifts that do not give              
          rise to gift taxes at the time of the gift may increase the net             
          tax due from the estate of the donor by virtue of their being               
          included in the "adjusted taxable gifts" of the estate for                  
          purposes of computing the estate tax.  The first $10,000 of a               
          gift or gifts made to a donee in a calendar year shall not be               
          included in the total amount of gifts made during the year, but             
          gifts of future interests in property do not qualify for the                
          exclusion.  Sec. 2503(b).                                                   
               Under section 2001(e), if a decedent's spouse was the donor            
          of any gift, one-half of which was considered under section 2513            
          as made by decedent, and the whole amount of such gift is                   
          includable in the gross estate of the decedent's spouse by reason           
          of section 2035, then such gift shall not be included in the                
          adjusted taxable gifts of decedent.  Generally the gross estate             
          includes any transfers of property made by a decedent within the            
          3-year period ending on the date of death, section 2035(a), but             
          that rule has been substantially narrowed for decedents dying               
          after 1981.  The general rule now does not apply to such                    
          decedents unless within the 3-year period the decedent made a               
          transfer of an interest in property that is includable in the               
          estate under section 2036, 2037, 2038, or 2042, or would be                 
          included under those sections had the interest been retained by             
          decedent.  Sec. 2035(d).  In the case at bar, no part of the gift           
          made in 1986 of the interest in real property owned by decedent's           




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