-17- petitioner and decedent agreed that petitioner would supply the labor to exploit the timber on her property and they would share the proceeds from the sales of timber and turpentine. Decedent's transfer of property to petitioner was not done as part of their business agreement; it was a separate, voluntary act by decedent. Petitioners point out that petitioner agreed in August 1980 to buy $150,000 worth of timber from the Putnam County property in order to close the sale of the property to the Thompson partnership. Petitioners contend that this shows the April 21, 1980, transfer of the undivided interest in the Putnam County property to petitioner was a business transaction. We disagree; decedent transferred the property to him 3� months before he agreed to buy the timber. It has not been shown that his agreement to buy timber was foreseeable when decedent transferred the property interest to him. Thus, we do not think the fact that petitioner agreed to buy timber from the Putnam County property supports petitioners' theory that decedent's transfer of the Putnam County property to him was made in the ordinary course of business. 4. Decedent's Gift Tax Returns and the Opinions of Decedent's Lawyers Petitioners contend that the lawyers who handled the two transfers did not believe that they were gifts. We disagree. First, the lawyer who prepared the 1980 deed testified that hePage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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