-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
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011