Larry L. Sather, Donor, et al. - Page 9




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          valued at $19,994 per gift.  Diane transferred to each of her               
          three children into the Duane Trust, 15 shares of Sathers stock             
          valued at $3,283 per gift.                                                  
               Larry, Kathy, John, Sandra, Duane, and Diane each filed a              
          gift tax return wherein they reported these transfers as gifts,             
          and each married couple elected to have all the gifts made by               
          them treated as made one-half by each of them for gift tax                  
          purposes.  See sec. 2513.  After application of the $10,000                 
          exclusion per donee (nine claimed by each donee), none of the               
          donors paid any gift tax.  The total value of transfers from each           
          married couple to their nieces and nephews and the total value of           
          property received by each niece and nephew are summarized as                
          follows:                                                                    
               Reported Value of                  Reported Value of                   
     Stock Transferred to                         Stock Received from                 
     Transferors       Nieces and Nephews           Transferees        Aunts and Uncles
     Larry and Kathy        $119,964    Nephew              $39,988                   
                                   Nephew                   39,988                    
                                        Nephew                 39,988                 
                                                       119,964                        
                                                                                     
     John and Sandra         119,964    Niece               39,988                    
                                        Niece               39,988                    
                                        Nephew                 39,988                 
                                                       119,964                        
     Duane and Diane         119,964                    Niece              39,988     
     Nephew             39,988                                                        
     Nephew                                                    39,988                 
                                                       119,964                        
               On December 31, 1992, and January 5, 1993, Rodney made gifts           
          of Sathers stock to each of his nine nieces and nephews in equal            
          amounts, and to Larry, Kathy, John, Sandra, Duane, and Diane in             






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