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court to act as co-personal representatives of the estate of
Birnie M. Davenport. A Form 706 United States Estate Tax Return
for the Estate of Birnie M. Davenport was filed timely on
November 7, 1991. The estate tax return filed on behalf of
petitioner was signed by Patricia L. Vestal and Gordon E.
Davenport as co-personal representatives of the estate. The
estate tax return showed tax due of $144,030, which was paid at
the time the return was filed.
A Form 709, United States Quarterly Gift Tax Return for 1980
(1980 gift tax return), was filed on behalf of Birnie
simultaneously with the estate tax return, on November 7, 1991.
The 1980 gift tax return was signed by Patricia L. Vestal and
Gordon E. Davenport. The 1980 gift tax return reflected a gift
of 537 shares of Hondo stock made on July 7, 1980, by Birnie to
Charles Botefuhr. For purposes of computation of the 1980 gift
tax, the estate valued the 537 shares of Hondo stock at $804 per
share. The 1980 gift tax return reflected a gift tax due in the
amount of $95,322, which was paid at the time that the return was
filed.
Birnie lived most of her adult life with her older sister,
Elizabeth Davenport (Elizabeth). Both Birnie and Elizabeth
remained unmarried and pursued careers with oil and gas
companies--Birnie as a legal secretary and Elizabeth as an
assistant to senior corporate executives. Both Birnie and
Elizabeth had extensive business experience.
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