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At least $616,864 of the $891,266 net proceeds of the Land
Bank loan was used to pay the taxes and expenses of Garry's
estate. Therefore, at least 65 percent of the gross proceeds of
the Land Bank loan (or at least 69 percent of the net proceeds)
was used to pay expenses that were the children's expenses, not
decedent's expenses.
The $274,402 remaining net proceeds of the Land Bank loan
was disbursed in four Land Bank checks. Three of these checks
were payable solely to Donald Hendrickson; the fourth was payable
collectively to Donald Hendrickson and the other signatories of
the note. These checks were then deposited into the Vera Lou
Klippel agent account, which was owned solely by the children.
The Land Bank's loan closing statement and supplemental
disbursement report provide very general information about the
use of these funds--that the funds were used to pay "legal fees",
"operating", or (apparently) miscellaneous equipment expenses--
but provide no details of those expenses or state on whose behalf
the expenses were paid.
Petitioner's estate tax return reported some of the Land
Bank stock, with a value of $12,980, as an asset of decedent's
estate.
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