- 62 - money's worth, she has made a gift. See sec. 2512(b); Dickman v. Commissioner, supra. More relevant to this case, one may spend her money on her own real estate without making a gift. However, when she spends her funds on someone else's real estate, without receiving adequate consideration, she has made a gift to that other person. See Pascarelli v. Commissioner, supra at 1099 (man's payment of landscaping and renovation expenses for house owned solely by woman held to be gift from man to woman, even though both lived in the house). Shortly after Garry's death, decedent began a program of giving her interest in the family farm land to the children. As a result, decedent's ownership of the farm land declined from 50 percent of the land in 1979 to 4.68 percent in 1992. For this reason, only a small portion of the expenses of the family farm represents expenses properly attributable to decedent for gift tax purposes. On average, decedent owned approximately 31 percent of the family farm land during the period in issue, 1979-93. The aggregate net cash needs of the family farm during this period did not exceed $239,184. We therefore estimate that during 1979- 93, approximately $74,147 (31 percent of $239,184) of decedent's investment income was used to pay family farm expenses properly attributable to decedent. Dividing this amount by the 15Page: Previous 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 Next
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