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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 during
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