- 13 - share. The IRS issued a notice of deficiency, and the estate of Elizabeth Davenport petitioned this Court. That case was captioned Estate of Davenport v. Commissioner, docket No. 26022-83. For purposes of the Tax Court litigation, the estate of Elizabeth Davenport was represented by Patricia Vestal and Gordon Davenport. Elizabeth's Federal estate tax case was settled by the parties without trial, and an agreed decision was entered on May 24, 1984. An agreement was signed by Gordon Davenport on April 18, 1984, and by Patricia Vestal on April 22, 1984, in which the basis of the settlement agreement with regard to stock of Hondo was set forth. In settling the case, the parties agreed that 1,610 shares of Hondo stock would be included in the gross estate of Elizabeth at a value of $2,400 per share. The Commissioner conceded the ownership issue, recognizing the split of ownership of assets by Elizabeth and Birnie. Birnie's last will and testament was drafted by Ms. Childs and was executed by Birnie on January 26, 1970. Elizabeth's last will and testament was drafted by Ms. Childs and was executed by Elizabeth on January 26, 1970. The sisters' wills contained mirror provisions. Both wills contained provisions for the distribution of each sister's respective interest in Hondo stock. The provision for distribution of Hondo stock in each of the sisters' wills was consistent with their joint ownership agreement.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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