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land exceeded the value of the private annuity she received.
Commissioner v. Wemyss, 324 U.S. at 306-307; sec. 25.2512-8, Gift
Tax Regs. In addition, in computing petitioner's estate tax
liability under section 2001, adjusted taxable gifts must be
increased to reflect decedent's August 1989 gift to her
grandchildren.
To reflect the foregoing and the parties' concessions,
Decision will be entered
under Rule 155.
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