Estate of Birnie M. Davenport, Deceased, Patricia L. Vestal, Personal Representative - Page 9

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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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