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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 15
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