Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Coexecutors, and Sharon Brockenbrough - Page 3

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               Section references are to the Internal Revenue Code.  Unless           
          otherwise indicated, Rule references are to the Tax Court Rules             
          of Practice and Procedure.                                                  
                                I.  FINDINGS OF FACT                                  
          A.   Petitioners                                                            
               Petitioners were married and lived in Gay, Georgia, when               
          they filed their petition.2  In 1993, the population of Gay was             
          about 125.                                                                  
               1.   Edward Brockenbrough                                              
               Petitioner Edward Brockenbrough (Mr. Brockenbrough) was born           
          in 1935.  His paternal and maternal grandparents operated                   
          dairies.  His parents were airplane pilots.  They owned about 300           
          acres of land on which they operated an airport and a farm with             
          cattle, horses, and pigs.  Mr. Brockenbrough milked cows every              
          day for 7 years when he was a child.  Mr. Brockenbrough took one            
          agricultural course and was a member of the Future Farmers of               
          America when he was in high school.  He graduated from college              
          with a degree in economics.  He left home after he graduated from           
          college.                                                                    
               Mr. Brockenbrough began working as a pilot for Delta                   
          Airlines (Delta) when he was 28 years old.  Federal law required            
          him to retire on August 8, 1995, when he reached the age of 60.             
          He had worked for Delta 31 years when he retired.  For the 15               

               2 Petitioner Edward Brockenbrough died after the trial was             
          held in this case.                                                          




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