Estate of Winifred Hughes, Deceased, Dean McBride, Executor and Trustee - Page 13

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         financial statements.  According to the estate tax return for the            
         Estate of Bob Hughes, the stock of Advance Leasing had a fair                
         market value of zero as of April 10, 1996.  Advance Leasing had              
         net losses of $66,672 for 1994, $50,995 for 1995, and $40,526 for            
         1996.  Even taking into account decedent’s $400,000 note, Advance            
         Leasing had a negative total net worth of $22,110 at the end of              
         1997 and $23,356 at the end of 1998.7                                        
              Advance Leasing used the entire $400,000 it received in 1999            
         from decedent to repay some of the more than $900,000 it then                
         owed to HELP.  Thus, the $400,000 payment to HELP directly                   
         benefited decedent’s children and grandchildren.                             
              We do not believe that the value of Advance Leasing’s stock             
         increased from zero on April 10, 1996 (as reported on the estate             
         tax return for Bob Hughes which McBride signed) to $400,000 on               
         April 29, 1997, and then fell to zero on July 25, 1999 (the date             
         decedent died, as reported on decedent’s estate tax return also              
         signed by McBride).  We conclude that the 4,000 shares issued to             
         decedent had little or no value when McBride signed the stock                
         subscription agreement on April 29, 1997.8  Thus, decedent did not           
         receive full and adequate consideration as required by section               

               7  As discussed supra, Advance Leasing’s 1997 and 1998                 
          financial statements did not reflect the additional 4,000 shares            
          issued to decedent and the $400,000 stock subscription agreement            
          note payable to Advance Leasing.                                            
               8  Neither party offered expert testimony on the value of              
          Advance Leasing stock on Apr. 29, 1997.                                     





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