Estate of Ona E. Hendrickson - Page 61





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          transferee, at the direction of the transferor, to pay the                   
          transferor's expenses.                                                       
               We have found that the net aggregate cash needs of the                  
          family farm from 1979 to 1993 did not exceed $239,184.  We                   
          believe, however, that even if decedent's investment income had              
          been used to pay this entire amount, only a portion of the amount            
          should be considered to be decedent's expenses, for the following            
          reason.                                                                      
               Petitioner asserts that an individual may consume her own               
          income as she wishes, without making a taxable gift.  Petitioner             
          also claims that decedent deeply desired to preserve the family              
          farm.  Accordingly, petitioner asserts that decedent, who had                
          both emotional and ownership interests in the family farm land,              
          could have spent as much money as she wanted on the farm without             
          making a taxable gift--even if she received no pecuniary return              
          on her investment.                                                           
               As a general principle, petitioner is undoubtedly correct               
          that an individual is under no duty to invest her property                   
          productively.  Indeed, an individual may consume or even squander            
          her property without making a gift.  See Dickman v. Commissioner,            
          465 U.S. at 340.  However, when an individual transfers her                  
          property (or the use of her property) to members of her family               
          without receiving adequate consideration for it in money or                  







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