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1) Whether Rebecca A. Wineman (decedent) retained a life
estate in partial interests in her homestead property transferred
to her children. We hold that she did not.
2) Whether decedent rented her ranch properties to a
closely held corporation owned by her children at below-market-
value rates, thereby making taxable gifts to her children. We
hold that she did.
3) Whether the cumulative fair market value of certain real
property includable in the gross estate was $2,261,800 as
returned by petitioner, $2,785,248 as determined by respondent,
or some other figure. We hold that the fair market value was
$2,417,491.
4) Whether petitioner’s election of special use valuation
qualified as a valid election under section 2032A.2 We hold that
it did.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
reference.
1(...continued)
property, the Homestead (parcel 3) and the Machado Ranch (parcel
8), were $52,000 and $231,000, respectively.
2All section references are to the Internal Revenue Code as
in effect for the date of decedent’s death, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
All monetary amounts have been rounded to the nearest dollar.
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