Estate of Austin Korby - Page 6

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          gave 24.5-percent limited partnership interests to irrevocable              
          trusts created for each of their four sons.  Approximately 90               
          percent of the transferred assets had been held by Austin and               
          Edna in joint tenancy.  The remaining 10 percent had been held by           
          Austin individually or in joint tenancy with his sons.  As a                
          result, Austin contributed 58.46 percent of KPLP’s assets, Edna             
          contributed 38.26 percent of KPLP’s assets, Austin and Edna’s               
          sons contributed 1.28 percent of KPLP’s assets, and the living              
          trust contributed 2 percent of KPLP’s assets.  After the                    
          transfers to the living trust and KPLP, Austin and Edna did not             
          have any bank accounts open in their own names.                             
               For 1995, Austin and Edna filed identical Forms 709, U.S.              
          Gift Tax Return, reporting gifts of 24.5 percent of KPLP’s                  
          limited partnership interests and 24.75 percent of Crane                    
          Properties’ limited partnership interests to each of their sons’            
          irrevocable trusts.  The gift tax returns reported the gifts as             
          split gifts; they were given half from each of Austin and Edna.             
          The gift tax returns also applied a 43.61-percent discount to the           
          value of the transferred KPLP interests because the interests               
          were minority interests and lacked management control.  The KPLP            
          interests were valued at $521,870 and the Crane Properties                  
          interests were valued at $78,160, for a total gift of $600,030.             
               After 1995, KPLP maintained five investment accounts at                
          various investment companies and a checking account.  Dividends             

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