Estate of Ellie B. Williams, Deceased, Robert M. Driggers, Sr., Personal Representative, et al. - Page 2

                                         -2-                                          
                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               COLVIN, Judge:  Respondent determined that petitioners are             
          liable for estate and gift tax deficiencies as follows:                     
                   Estate of Ellie B. Williams, docket No. 219-96                     
                                   Deficiency                                         
                                   $157,969.25                                        
                Robert M. Driggers, Sr., Transferee, docket No. 220-96                
                         Year                     Deficiency                          
                         1980                     $192,556.20                         
                         1983                     328,518.00                          
                Estate of Ellie B. Williams, Donor, docket No. 221-96                 
                         Year                     Deficiency                          
                         1980                     $192,556.20                         
                         1983                     328,518.00                          
               The issues for decision are:                                           
               1.   Whether transfers by Ellie B. Williams (decedent) in              
          1980 and 1983 of undivided one-half interests in timberland to              
          Robert M. Driggers, Sr. (petitioner), were gifts, as respondent             
          contends, or compensation for services, as petitioners contend.             
          We hold that they were gifts.                                               
               2.   Whether the fair market values of the undivided one-              
          half interests in timberland decedent gave petitioner in 1980 and           










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