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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.
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