Estate of Carolyn W. Holland, Deceased, Jack K. Holland, Lewis G. Holland, Sr., and Betty H. Kann, Executors - Page 8

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          annual exclusion from taxable gifts provided by section 2503(b)             
          to make a series of annual gifts with a fair market value of                
          $10,000 to each of her three children.  After a discussion with             
          her children, decedent agreed to transfer to each child, and each           
          child agreed to accept, one-ninth of her interest in the                    
          Weinstock Residence in 1984, 1985, and 1986 (a transfer of one-             
          ninth of her interest each year to each child).                             
               In August 1984, due to an error in drafting the conveyance,            
          decedent transferred by deed her entire interest in the Weinstock           
          Residence to her three children.  That is, decedent transferred             
          nine-ninths of her interest, described in the deed as an interest           
          in fee simple, instead of the three-ninths she intended to                  
          transfer.  Unaware of the error, the transferees recorded this              
          deed on January 22, 1985.  Decedent executed deeds in 1985 and              
          1986 that purported in each of those years to convey an                     
          additional one-ninth of her interest to each child.  The 1985 and           
          1986 deeds were not recorded by the children-transferees.                   
               The Sale of the Weinstock Property                                     
               In May 1987, all of the parties owning interests in the                
          Weinstock Property entered into an agreement to sell the entire             
          Weinstock Property to a potential buyer (Purchaser).  At the time           
          of the agreement, the owners of the 28.75-acre portion, and their           
          ownership percentages, were as follows:  the Carolyn Trust, 32.5            
          percent, the Nathan Trust, 32.5 percent, decedent, 17.5 percent,            
          and Mrs. Nathan, 17.5 percent.  The remaining acreage was owned             
          by decedent, individually, Mrs. Nathan, individually, and the JKH           



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