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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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