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Walker). Ms. Thompson attended one or two of the meetings at
which the discussions took place. Mr. Walker discussed ways to
reduce Mr. and Mrs. Pruitt’s projected estate tax liability and
advised them on the effect of the Federal gift tax, gifting
schedules, and charitable donations. Mr. and Mrs. Pruitt were
concerned about the considerable size of their estate and
potential estate tax problems. Mr. and Mrs. Pruitt wanted their
children to inherit as much of their estate as possible.
From 1980 through 1992, in accordance with Mr. Walker’s
advice, decedent engaged in a pattern of making gifts to her
daughters, their husbands, and her grandchildren in an attempt to
reduce the size of her estate. Decedent personally made all the
gifts during this period. The gifts made by decedent from 1980
through 1992 were as follows:
Donee1 Date of Gift Amount
Robyn Muckerheide 1980 $1,000
Sharon K. Phillips 1,000
Sandra S. Thompson 1,000
Robyn Muckerheide 1981 1,000
Sharon K. Phillips 1,000
Sandra S. Thompson 1,000
Robyn Muckerheide 1982 1,000
Sharon K. Phillips 1,000
Sandra S. Thompson 1,000
Robyn Muckerheide 1983 2,000
Sharon K. Phillips 2,000
Sandra S. Thompson 2,000
Robyn Muckerheide 1984 3,000
Sharon K. Phillips 3,000
Sandra S. Thompson 3,000
Robyn Muckerheide 1985 3,000
Sharon K. Phillips 3,000
Sandra S. Thompson 3,000
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