- 12 - On August 29, 1989, Janet's husband executed a Consent of Spouse, pursuant to which he agreed to abide by the terms of the partnership agreement. On August 30, 1989, decedent's grandchildren by warranty deed conveyed to their Cullison Enterprises partnership the land decedent had transferred to them. This warranty deed, which had been executed by them on August 30, 1989, was recorded by them on September 8, 1989. From late 1988 until August 29, 1989, decedent continued to be the land's sole owner. Decedent was entitled to the rents payable by tenants for their use of the land until that date, and she was also liable for any real property taxes imposed covering the period of her ownership up until that date. From September 1, 1990, through January 19, 1992, decedent's grandchildren never made any of the annual payments they owed to decedent pursuant to the annuity agreement. Decedent died on January 19, 1992, when she was 84 years and 2 months old. Neither decedent nor petitioner ever filed any Federal gift tax returns. During the examination of petitioner's estate tax return, the Internal Revenue Service (IRS) estate tax examiner asked Mr. Shadle (who was petitioner's attorney) to obtain and provide him with an appraisal report concerning the value of the land decedent had transferred to her grandchildren. As a result, Mr.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011