- 21 - determined that decedent had made taxable gifts to her children amounting to $53,784 that are properly includable in decedent's adjusted taxable gifts. Only $23,784 of that determination remains at issue and encompasses two types of gifts: (1) Checks of $10,000 delivered to each of decedent's three children and (2) below-market-value rental of decedent's ranch properties. After reducing the amount of the gifts by $10,000 to account for the annual exclusion, respondent determined that decedent had made taxable gifts to her children amounting to $5,595 in 1989, $11,595 in 1990, and $6,594 in 1991. The parties stipulated that decedent made the first type of gifts. Respondent asserts that the information submitted by petitioner’s expert on comparable rentals demonstrates that decedent's rate of rent was less than the market rate. Petitioner argues that decedent charged a market rate because Coastal Ranches paid various property-related expenses. We agree with respondent. Petitioner's special use valuation report indicated that the annual fair market rent of decedent's pro rata interest in the parcels rented to Coastal Ranches was $14,725. The report did not identify a fair market rent for parcel 3. Respondent estimated that the annual fair market rent of decedent's 51- percent interest in parcel 3's land and improvements (excludingPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011