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Petitioner claims that decedent spent most or all of her
investment income on the family farm, either as part of a bona
fide business venture with the children or for her own account
and pleasure. We have found that decedent became entitled to
$913,200 of net investment income during 1979-93. However, we
have also found that the aggregate net cash needs of the family
farm during that period did not exceed $239,184. Therefore, even
if decedent had supplied all the cash needed by the farm, this
would only have accounted for about one-fourth of decedent's
investment income from Garry's estate. Accordingly, we conclude
that most of decedent's income simply was not spent on the family
farm, notwithstanding petitioner's contentions.9 We also
conclude that decedent did not receive the consideration claimed
by petitioner for any investment income not spent on farm
expenses.
In effect, decedent's conduct or acquiescence during the
lengthy period of administration of Garry's estate--both as a
beneficiary and as personal representative--prevented the
9 Donald Hendrickson testified at trial that he personally
borrowed about $600,000 for the expenses of the family farm and
spent more of his own money than that on family farm operations.
In light of our finding that the net cash needs of the family
farm during 1979-93 did not exceed $239,184, we conclude it is
quite unlikely that Donald Hendrickson spent such sums on the
family farm--although he may well have spent that much on some of
the other Hendrickson family farming operations he also managed,
including a farm owned by the children that was contiguous with
parts of the family farm.
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