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of his will. Walker's total gross estate consisted of the
following assets:
A. Real estate $222,000.00
B. Stocks and bonds 5,320.59
C. Mortgages, notes and
cash 255.00
D. Life insurance 6,000.00
E. Jointly-owned property 92.76
F. Other misc. property 22,500.00
Total gross estate 256,168.35
The deductions for Walker's estate were as follows:
J. Funeral expenses and
other expenses $4,626.98
K. Debts of decedent 20,516.16
L. Mortgages and liens 162,815.81
Total 187,958.95
Adjusted gross estate 68,209.40
The estate tax return showed that, at the time of his death,
Walker had no cash on hand or on deposit in any bank. While
Walker had a safe deposit box, it contained no money. No
transfers of property within 3 years of Walker's death were
reported on Schedule G, Transfers During Decedent's Life,
attached to the Form 706, United States Estate Tax Return, filed
by Jean, nor was any gift tax return filed by or for Walker. The
Walker estate tax return was accepted as filed by the IRS by
letter dated January 13, 1978.
C. Petitioner's Education, Employment, and Living
Arrangements
After graduating from high school in 1982, petitioner
attended St. Catherine's Community College (St. Catherine's) in
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