-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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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