-8- 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 JKHPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011