-3- 1983 are $211,000 and $221,000, as petitioners contend; $784,700 and $989,662.50, as respondent contends; or some other amounts. We hold that the value of the 1980 gift is $379,960 and the value of the 1983 gift is $486,150. 3. Whether petitioner is liable as a transferee for decedent's gift tax deficiencies for 1980 and 1983. We hold that he is. 4. Whether the fair market value of decedent's undivided one-half interest in 843.26 acres of timberland when she died was $143,000, as petitioners contend; $360,500, as respondent contends; or some other amount. We hold that the value of the timberland was $177,085. 5. Whether, as respondent contends, the fair market value of a 1992 Cadillac Brougham was $24,500 at the date of decedent's death. We hold that it was. Section references are to the Internal Revenue Code. Rule references are to the Tax Court Rules of Practice and Procedure. I. FINDINGS OF FACT A. Petitioners 1. Ellie B. Williams Ellie B. Williams (decedent) was born in April 1908. Her husband was Frank Williams (Williams). They had no children. Williams died on September 4, 1962. Decedent inherited aboutPage: 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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