-22-                                          
          receive a greater rate of interest than if they had each bought a           
          CD in the amount of the individual gifts.                                   
               Pledging the CD's as security for Jack's guarantee benefited           
          decedent by lowering her cost of borrowing.  When Jack executed             
          the loan agreement on behalf of decedent, he negotiated the rate            
          of interest that the bank would charge for the loan with the                
          bank's representative, Mr. Marshall Wellborn (Wellborn).                    
          Wellborn and Jack were friends, and the bank regarded the Holland           
          family as a valuable account.  Accordingly, the bank accepted               
          Jack's strategy to make the loan "self-funding" by accepting his            
          pledge of the CD as security for his guarantee.  The interest               
          rate on a self-funded loan was only 1-� percent above the                   
          interest rate paid on the $120,000 CD.  First National did not              
          require the CD to be pledged for it to make the loan; however,              
          without the pledge the interest rate on the loan would have been            
          higher.  Therefore, the purpose of pledging the CD as security              
          for Jack's guarantee of decedent's unsecured loan was to reduce             
          decedent's cost of borrowing.                                               
               Decedent paid the interest on the loans when it became due,            
          and the donees received the interest paid each month by First               
          National on the CD's.  Each year, Jack issued a Form 1099 to each           
          donee reporting the amount of interest paid, and each of the                
          Weinstock Trusts filed Federal and State income tax returns for             
          1985, 1986, 1987, 1988, and 1989, reporting the interest received           
          on the CD's.                                                                
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