-13-
2. Love and Affection Between Petitioner and Decedent
Decedent and her husband had no children. After decedent's
husband died in 1962, petitioner, whose wife was Williams' niece,
handled many important personal matters for decedent. Petitioner
testified that he did not expect to be paid for performing these
personal services, and that he loved decedent like a mother and
she loved him like a son. Their close personal relationship
suggests that decedent gave interests in the Putnam County and
Clay County properties to petitioner out of love and affection.
Decedent was clearly inclined to make gifts to petitioner.
Decedent gave $283,000 to petitioner when she sold 4,200 acres of
timberland in 1979. Decedent gave $10,000 to petitioner in 1987
and another $10,000 in 1991 as advances on his inheritance from
her. Decedent left most of her estate to petitioner. See Cobb
v. Commissioner, T.C. Memo. 1985-208 (in deciding whether
decedent's grant of an option to buy her farm was a gift, Court
considered whether decedent had previously made gifts to the
optionee).
Petitioner received 75 percent of the receipts (less
expenses) from the sale of turpentine and one-half of the profits
from the sale of timber. Petitioners do not contend that
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