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(Beck) (an attorney for Beth W. Corp. and decedent), and Irwin A.
Weiser (Weiser). Decedent transferred Beth W. Corp. stock to the
irrevocable trusts during her life.
1. Revocable Trust
Decedent was the beneficiary of the revocable trust during
her lifetime. After she died, the beneficiaries of the revocable
trust were her husband, Clifford Gray; her sister, Gladys White;
her nephew, Rex Deason; her granddaughter, Pollett; and three
great-grandchildren. Decedent transferred 7,991 shares of Beth
W. Corp. stock to the revocable trust in 1987.
Decedent transferred 534 shares of Beth W. Corp. stock from
the revocable trust to Beth W. Corp. (454 shares on June 30, 1987
and 80 shares on July 31, 1988). Decedent reported the amount
received in exchange for the June 30, 1987, transfer as a
$270,062 dividend on her 1987 Federal income tax return. She
reported the amount received in exchange for the July 31, 1988,
transfer as a $45,146 dividend on her 1988 Federal income tax
return.
2. Irrevocable Trust #1
Clifford Gray was the income beneficiary of irrevocable
trust #1. The trust agreements stated that when he died, the
remainder was to be distributed to irrevocable trust #2.
Decedent transferred 765 shares of Beth W. Corp. stock to
irrevocable trust #1 on December 23, 1986. She reported on her
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