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3. Practice of Law by Decedent’s Son-in-Law and Decedent’s
Formal Gift-Giving Program
Decedent’s son-in-law has practiced as an attorney for more
than 50 years, and he has regularly attended seminars on estate
planning and the Federal estate tax. Throughout his practice, he
has advised decedent on various legal matters including
establishing a formal plan to make gifts to her descendants and
their spouses (collectively, descendants). Decedent’s wealth
consisted primarily of stocks, bonds, and cash. Decedent’s
son-in-law most likely recommended the formal plan of gift giving
as a form of estate planning.
In 1979, decedent began the formal gift-giving plan under
which she (in her own capacity or apparently after 1994 through
her daughter as decedent’s attorney-in-fact) generally gave her
descendants gifts in each of the ensuing years until her death.
Before 1995, decedent and her daughter usually met once a year in
Chicago to select any particular stock or bond that would be
given to each donee descendant. Decedent’s son-in-law kept
records detailing these gifts. In 1995 and 1996, decedent
(through her daughter as decedent’s attorney-in-fact) gave cash
to her then 16 descendants as follows:2
2 We note that Jacob Silver and Benjamin Silver each
received $5,000 a year in 1995 and 1996, while all of the other
listed individuals who were not decedent’s children each received
$10,000 a year. We are unable to find the reason the two named
individuals were treated differently.
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