DEEN, Presiding Judge.
In 1972, Norman G. Davenport sold a piece of real estate for which he received a promissory note in the amount of $273,954.27. Davenport's interest in the note was transferred through his estate in 1978 to his sister Ada Davenport. A short time later, Ada Davenport met with an attorney to plan the estate and gift tax consequences of a transfer of a portion of her interest in the note to her brother, Verlie Davenport, and her nephew, Calvin Coolidge...
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