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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 he
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