Estate of H.A. True, Jr. - Page 292




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              C.  1994 Transfers by Jean True                                         
              After Dave True died, Jean True no longer wished to be                  
          actively involved in all the True companies.  Accordingly, on               
          June 30 and July 1, 1994, she gave notice to her sons of her                
          intent to sell most of her interests in the True companies.  Jean           
          True sold her interests to her sons at book value, pursuant to              
          the terms of the buy-sell agreements.                                       
              Jean True timely filed a 1994 Federal gift tax return                   
          disclosing the transactions but treating them as sales, thereby             
          reporting no taxable gifts.                                                 
              On January 20, 1998, respondent issued to Jean True a notice            
          of deficiency (1994 gift tax notice), determining that the values           
          of interests she sold in 1994 were higher than reported book                
          values.  However, since issuing the 1994 gift tax notice,                   
          respondent has conceded the reported values of interests in                 
          Roughrider Pipeline Co., Rancho Verdad, Toolpushers Supply Co.,             
          and Midland Financial Corp. that were sold by Jean True in 1994.            
          Appendix schedule 3, infra, lists the interests sold and compares           
          the 1994 gift tax notice values to amounts paid by the                      
          purchasers.                                                                 
          IV. Subsequent Income Tax Litigation Regarding Ranchland                    
              Exchange Transactions                                                   
              During the 1980's, the True family (except Tamma Hatten)                
          purchased land and operating assets to add to their ranching                
          operations.  Each purchase took place through the same series of            





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