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Facts Relating to Petitioner's Secondary Position--Use of
Decedent's Investment Income To Pay Expenses of Family Farm;
Consideration Received by Decedent for Any Investment Income Not
So Used
During 1979-93, decedent became entitled to $913,200 of net
investment income.
The net cash needs of the family farm during 1979-93 did not
exceed $239,184.
As shown by petitioner's own "accounting" of Garry's estate,
at least $443,000 of decedent's funds was not used to pay
decedent's expenses.
Most of decedent's $913,200 in net investment income was not
used to pay family farm expenses; the amount of decedent's income
so used did not exceed $239,184.
HEI Receivable
There are no notes or other written agreements evidencing
any loans from Garry's estate or decedent to HEI.
The Federal estate tax return of Garry's estate reported, as
one of the assets of Garry's estate, a receivable from HEI in the
amount of $359,534. The Federal estate tax return of decedent's
estate also reported a receivable from HEI in the amount of
$166,500.
On its Federal fiduciary income tax returns for the fiscal
years ending February 1980 through February 1994, Garry's estate
reported approximately $467,000 of interest income from HEI.
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