Estate of Lloyd P. Cavett - Page 17




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          relationship that existed between Bell and decedent.  We believe            
          that Bell’s willingness to perform those services proceeded from            
          love and affection and not from any expectation of profit.  We              
          likewise believe that decedent understood that those services               
          were performed out of feelings of love and affection, and not in            
          expectation of any profit.  If the services to decedent sprang              
          from love and affection, the services themselves are tantamount             
          to an expression of love and affection, which cannot be reduced             
          to money or money’s worth.  See sec. 25.2512-8, Gift Tax Regs.              
          By the Agreement, decedent agrees to leave Bell no less than what           
          he left to her in his 1981 will.  By the 1981 will, decedent                
          devised Bell his house and bequeathed to her his personal                   
          property, $100,000, and three grave sites.  Other than decedent’s           
          daughter, Bell is by far the most favored beneficiary under the             
          1981 will.  By a codicil executed in December 1982, decedent                
          increased the cash bequest to Bell by $100,000.  By the 1981                
          will, decedent also left substantial sums not only to Bell’s                
          children but also to her grandchild.  We cannot reconcile the               
          generosity of those provisions with an employment relationship.             
          See, e.g., Reynolds v. Commissioner, T.C. Memo. 1999-62.                    
               C.  The 1981 Will                                                      
               Petitioners argue that the 1981 will shows that Bell was an            
          employee of decedent.  By the 1981 will, decedent provided for              
          the care of his invalid adult daughter.  He also provided that “a           






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