MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
Respondent determined a deficiency in Federal gift tax against petitioner for 1989 of $559,435 and a deficiency in Federal estate tax of $506,298.
After concessions, the issues for decision are:
(1) Whether Suzanne W. Cullison (decedent) transferred four parcels of farmland totaling approximately 530 acres to her grandchildren in late 1988, rather than on August 29, 1989. We hold the transfer...
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