Estate of Ona E. Hendrickson - Page 62





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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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