- 14 - In the notice of deficiency dated March 21, 1996, respondent determined, among other things, that in calculating petitioner's estate tax liability, adjusted taxable gifts should be increased as a result of decedent's 1989 gift of land to her grandchildren. In its petition seeking review of the above two notices of deficiency, petitioner maintained that decedent had transferred the land to her grandchildren on or about August 29, 1989. The petition alleged, in pertinent part: 5. Facts upon which Petitioner relies, as the basis of Petitioner's case, are as follows: * * * * * * * b. On or about August 29, 1989, the Decedent, being then a single woman, entered into an agreement with her four grandchildren pursuant to which she transferred to them farming property of substantial value. c. In consideration of the foregoing transfer of ownership, the four children contemporaneously agreed to pay, on the first day of September beginning with the year 1990, an annuity payment of $311,165 for as long as Decedent might live. d. The transfer of real estate was a transfer for full and adequate consideration and was not a taxable gift.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011