Estate of Marie A. Bies - Page 2

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            closely held corporation stock made by Marie A. Bies (decedent)                            
            to two daughters-in-law during the years 1985 through 1995, and                            
            to a granddaughter-in-law during the years 1991 through 1995,                              
            were, in substance, indirect transfers of stock to decedent's                              
            sons and grandson.  We hold they were.                                                     
                                         FINDINGS OF FACT                                              
                  Some of the facts have been stipulated and are so found.                             
            The stipulation of facts and the accompanying exhibits are                                 
            incorporated herein by this reference.  Decedent died testate on                           
            July 9, 1995, in Roseville, Minnesota (Roseville).  At the time                            
            the petition in this case was filed, the personal representative                           
            of the estate, Larry D. Dunn, resided in St. Paul, Minnesota (St.                          
            The Bies Family                                                                            
                  Decedent married Albert N. Bies (Albert Sr. or her husband;                          
            collectively, when referring to them both, the Bieses) in 1938                             
            and remained married to him until his death on May 12, 1990.  The                          
            Bieses had four children, Joanne, Albert, Barbara, and Gregory                             
            (collectively, the Bies children).                                                         
                  James C. Nielsen, Sr. (James Sr.), and Joanne married in                             

            increased the value of the gross estate reported on the estate                             
            tax return.  Petitioner assigned error to all these                                        
                  The parties have agreed that any issues they are unable to                           
            settle will be tried later.                                                                

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