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Creation of the Liechtenstein Corporation
On August 30, 1994 (the last day David and Mr. McGuire
discussed these cases), David executed a warranty deed,
transferring the real property located at 1221 Harney Street,
Omaha, Nebraska (the property where the offices of Baum were
located), to the Christiania Corp., AG, of Vaduz, Liechtenstein,
for a stated consideration of $1. On October 6, 1994, David filed
the warranty deed with the Douglas County Registry of Deeds
reflecting that he had sold this real property to the Christiania
Corp.
On May 29, 1995, through an accountant to whom he had given
his power of attorney, David filed a 1994 Form 709, U.S. Gift and
Generation-Skipping Transfer Tax Return. Reflected on this form
were two gifts David made to Christiania Corp.: (1) On August 30,
1994, David gave the corporation his residence (including a house,
lot, and garage) at 3722 Dewey Drive, Omaha, Nebraska, and (2) on
September 15, 1994, David gave the corporation his 1,184 shares of
Baum stock (representing 100 percent of Baum's outstanding shares
of stock).
ULTIMATE FINDINGS OF FACT
1. Sloan died on March 8, 1987, with a gross taxable estate
of $11,606,904. Following Sloan's death, David took possession of
Sloan's assets. David is the executor of Sloan’s estate within the
purview of section 2203.
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