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OPINION
Section 2001(a) imposes an estate tax on the transfer of the
taxable estate of every decedent who is a citizen or resident of
the United States. The tax imposed is equal to the excess of the
tentative tax on the sum of the amount of the taxable estate and
the amount of adjusted taxable gifts, over the amount of tax
which would have been payable as a gift tax with respect to gifts
made by a decedent after December 31, 1976. Sec. 2001(b). The
term "adjusted taxable gifts" means the total amount of taxable
gifts (within the meaning of section 2503) made by a decedent
after December 31, 1976, other than gifts which are included in
the gross estate of the decedent. Sec. 2001(b). Section 2503(a)
defines "taxable gifts" as the total amount of gifts made during
a calendar year, less certain statutory deductions. Thus,
decedent's transfer of her farmland constitutes an adjusted
taxable gift within the meaning of section 2001 only if it is
also a taxable gift within the meaning of section 2503. See
Estate of DiMarco v. Commissioner, 87 T.C. 653, 656-657 (1986).
Section 2501 imposes a tax on property transferred by gift.
Sec. 2501(a); see also sec. 2511(a). If property is transferred
for less than adequate and full consideration in money or money's
worth, the amount by which the value of the property exceeds the
value of the consideration is deemed a gift. Sec. 2512(b);
Commissioner v. Wemyss, 324 U.S. 303, 306-307 (1945). In
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