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According to the "accounting" of Garry's estate introduced
by petitioner at trial, the payments Garry's estate received from
HEI during 1979-93 totaled approximately $411,000. Many of these
payments were referred to as interest in the accounting.
The payments Garry's estate received from HEI during 1979-93
were therefore less than the amount of interest owed by HEI
during that period.
HEI did not pay off the $359,534 receivable reported on the
estate tax return of Garry's estate.
The $166,500 HEI receivable reported on petitioner's estate
tax return is part of the same receivable reported on Garry's
estate tax return.
Garry's estate did not use any of decedent's investment
income to acquire the $166,500 receivable from HEI (or to acquire
any other receivable from HEI during 1979-93).
Children's Performance of Services for Family Farm
During 1979-93, Donald Hendrickson and Mrs. Klippel each
performed not more than 10 hours per week of services relating to
the family farm, with values of $15 per hour and $8 per hour,
respectively. James O. Hendrickson did not perform any material
services relating to the family farm during that period.
The aggregate value of the services performed by the
children relating to the family farm during 1979-93 therefore did
not exceed $172,500 (i.e., 10 hours per week, times 50 weeks per
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