30 Sometime from December 22, 1990, to January 2, 1991, Mike and Peter Brown gave Paul Brown promissory notes for $126,412.50 and $166,412.50, respectively, as partial consideration for the Brown family partnership units. Both notes were paid in full, with interest, in January 1991. On January 2, 1991, Paul Brown forgave $20,000 of each of the debts incurred by Mike and Peter Brown. The partnership was later dissolved. Its assets (the Sawyer note and option) were distributed to the partners, pro rata, according to partnership units held. 2. Paul Brown's Gifts of Partnership Interests and Forgiveness of Related Debt Paul Brown and his wife, Mary Brown, filed Federal gift tax returns (Forms 709) for the tax years 1983 to 1986, 1990, and 1991. They used the annual per donee exclusions from gifts (section 2503), and the gift splitting provisions (section 2513) in each of those years, and the unified credit (section 2010) in 1983-86. On their Forms 709 for 1984, 1985, and 1986, Paul and Mary Brown reported that the donor's adjusted basis was zero for all gifts. Paul Brown reported making the following gifts in 1983-86 and 1990-91:Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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