Estate of Pattie Welder Edwards - Page 2

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          date of death were encumbered by oral options that extended the             
          existing leases on the ranch properties and, if so, whether the             
          oral options or the existing leases were a restriction on the               
          sale or use of the ranch properties that should be disregarded              
          for estate tax valuation purposes under section 2703.                       
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect on the date of decedent’s               
          death, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
               Pattie Welder Edwards (decedent) died on December 20, 1994.            
          At the time of her death, decedent was a resident of Nueces                 
          County, Texas.  Decedent’s children, Oakes David Edwards, Jr.               
          (Edwards), and Patricia Edwards Carson (Carson), are the                    
          coexecutors of the estate.  At the time of filing of the                    
          petition, Edwards resided in Sinton, Texas, and Carson resided in           
          Mountain Home, Texas.                                                       
               Decedent devised her jewelry, personal property, and the               
          remainder of her estate to her children, Edwards and Carson, in             
          equal shares.  The last will and testament of decedent dated                
          July 27, 1988, states in part:                                              
                    I GIVE, DEVISE and BEQUEATH all the rest, residue                 
               and remainder of my estate, whether real, personal or                  

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