Estate of Lewis A. Bailey, Deceased, Frances Jeanette Foster, Executrix - Page 2

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          qualified terminable interest property (QTIP) trust established             
          by decedent’s predeceased first wife and that is includable in              
          decedent’s gross estate pursuant to section 2044; (3) the amount,           
          if any, of net taxable gifts arising with respect to the 1995               
          assignment to decedent’s children of a promissory note; (4) the             
          amount, if any, of decedent’s unreported taxable gifts in 1993              
          and 1989; and (5) the amount deductible under section 2053(a)(2)            
          as administration expenses of the estate.1                                  
                                  FINDINGS OF FACT                                    
               The parties have stipulated some facts, which we                       
          incorporate, along with the associated exhibits, into our                   
               Lewis A. Bailey (decedent) died on December 18, 1995.  His             
          domicile at death was in Garland County, Arkansas.  When the                
          petition was filed, the executrix resided in Hot Springs,                   
          C&L Bailey                                                                  
               In 1985, decedent and his wife, Ethel C. Bailey (Ethel),               
          incorporated C&L Bailey, an Arkansas nonpublicly traded                     

               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code in effect at the date of decedent’s               
          death, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     

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