- 12 - Daniel's claim against the estate is for all practical purposes the same as David's, and we believe that the same considerations warrant our holding that the mutual, arm's-length promises of decedent and Daniel constituted adequate and full consideration in money's worth. The fact that the amount of the settlement disposing of Daniel's claim was somewhat greater than David's settlement has no bearing on our finding. Settlement figures are generally arrived at after considering the uncertainties of litigation. However, our focus in analyzing the adequate and full consideration issue falls on the point at which decedent and Daniel decided to make their bargain. Decision will be entered under Rule 155. 3(...continued) Estate of Boyce v. Commissioner, supra. In the instant case, both David and Daniel agreed to treat the settlement payments as compensation received.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
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