Estate of Paul E. Brown, Deceased, Peter D. Brown and Michael Brown, Co-Executors - Page 30

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               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:                                                                








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