- 5 - them. See sec. 25.2512-8, Gift Tax Regs. Petitioner alternatively argues that even if no bona fide farm partnership existed, decedent still made no gifts of the investment income because most or all of the income was spent on decedent's share of the family farm's expenses. Petitioner further asserts that decedent received full consideration for any income not so spent by reason of the children's performance of services for the family farm and the receipt of an indebtedness from Hendricksons Enterprise, Inc., a corporation whose shares were owned by the children and decedent. Any taxable gifts we find decedent made during 1979-93 must be taken into account in computing petitioner's estate tax under section 2001(b). In addition, respondent, in a separate notice, also determined deficiencies in decedent's Federal gift taxes for 1980-92 on the basis of the same gifts determined in the estate tax notice at issue herein. No petition was filed with this Court concerning the gift tax notice. As of the time of trial, respondent had assessed the gift tax deficiencies but had taken no action to collect them. Respondent's counsel has informed the Court that respondent will follow the Court's conclusions in this case as to the amount of decedent's lifetime taxable gifts, in any future collection actions with respect to the gift tax assessments. As a result, any gifts we find decedent made duringPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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