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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 about
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