Estate of Birnie M. Davenport, Deceased, Patricia L. Vestal, Personal Representative - Page 13

                                                - 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

Last modified: May 25, 2011