Estate of Suzanne W. Cullison, Deceased, J. Greg Cullison, Personal Representative - Page 14

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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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