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reported a receivable from HEI as an asset of the estate.
Petitioner claims that the two returns did not refer to the same
receivable. According to petitioner, HEI paid off the $359,534
receivable reported on Garry's estate tax return over several
years following Garry's death, and the $166,500 receivable
reported on petitioner's return was a new asset acquired
subsequently by Garry's estate on behalf of decedent.
The evidence does not support petitioner's assertions. To
the contrary, it shows that the same receivable was reported on
both returns. Having found that none of decedent's funds were
used by Garry's estate to acquire a receivable from HEI during
1979-93, we have also found that decedent received no
consideration for her investment income in the form of a
receivable from HEI.
With respect to the children's provision of services to the
family farm, we have found that Donald Hendrickson and Mrs.
Klippel performed some services during 1979-93 with respect to
the operations of the family farm. However, we now hold that
these services do not constitute "consideration" for decedent's
investment income within the meaning of the gift tax, for the
following reasons.
The children owned 50 percent of the family farm land after
Garry's death in 1979. Their ownership of the farm land then
increased continuously until 1992, when it reached 95.32
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