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(1) Whether Suzanne W. Cullison (decedent) transferred four
parcels of farmland totaling approximately 530 acres to her
grandchildren in late 1988, rather than on August 29, 1989. We
hold the transfer occurred on August 29, 1989.
(2) The fair market value of the farmland, as of the date of
its transfer by decedent to her grandchildren. We find it was
$1,865,500.
(3) The value of the private annuity the grandchildren
agreed to pay decedent in exchange for the farmland. We find it
was $1,360,724.
(4) Whether the private annuity transaction qualifies as a
transaction in the ordinary course of business under section
25.2512-8, Gift Tax Regs. We hold that it does not.
All section references are to the Internal Revenue Code in
effect either at the date of transfer or the date of decedent's
death (whichever is applicable), and all Rule references are to
the Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
FINDINGS OF FACT
Some of the facts and certain documents have been stipulated
for trial pursuant to Rule 91 and are found accordingly. We
incorporate the parties' stipulations in this opinion by
reference.
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