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By reason of having become entitled under Garry's will to 50
percent of the coal royalties, dividends, and interest, decedent
became entitled to $999,769 of the investment income of Garry's
estate during 1979-93, as shown in the foregoing table.
At the time of Garry's death, the value of the Gibson County
coal mining rights was approximately $1.5 million; the value of
decedent's 50-percent interest in those rights was approximately
$750,000. By the time of decedent’s death, the value of
decedent's interest had declined to $268,805.
Distributions From Garry's Estate to Decedent
Notwithstanding the approximately $2 million in investment
income Garry's estate received--and the $1.8 million excess of
that income over the aggregate net cash needs of the family
farm--Garry's estate made few distributions to decedent during
1979-93. The Federal fiduciary income tax returns of Garry's
estate do not claim any distribution deductions for any of the
fiscal years ending from February 1980 through February 1994.
However, respondent has conceded that $14,303 in coal royalties
was distributed to decedent as follows: $3,803 in 1979; $7,500
in 1980; and $3,000 in 1989. These were the only distributions
by Garry's estate to decedent during 1979-93.
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