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In January 1986, decedent and petitioner sold 329.26 acres
of the Clay County property to National Training, Inc., for
$911.13 per acre. The parcel sold was 95 percent uplands and 5
percent wetlands.
5. Decedent's Gifts of $10,000 to Petitioner in 1987
On February 20, 1987, decedent gave petitioner $10,000. The
memo section of the check said "Bequest". On March 8, 1991,
decedent again gave petitioner $10,000. Decedent wrote
"advancement on inheritance" in the memo section of the check.
6. Decedent's Will
In her will, decedent made small bequests to petitioner's
son and granddaughter and other distant relatives. She left most
of her estate to petitioner.
When decedent died, she owned an undivided one-half interest
in 843 acres of undeveloped, rural land in Clay County (the
estate property), about 79 percent (643 acres) of which was
wetlands, and a 1992 Cadillac Brougham worth $24,500. She
transferred or sold most of the 2,315 acres in Clay County and
2,360 acres in Putnam County before she died.
C. Decedent's Estate and Gift Tax Returns
Decedent did not file gift tax returns or pay gift tax for
her 1980 and 1983 transfers to petitioner. After decedent died,
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Last modified: May 25, 2011