BobKamman
Level 15

Was this a completed gift?  Seems to me that Mom "gave" the kids the property (probably, so the taxpayers and not they would have to pay for her nursing-home costs) in return for the right to live there for the rest of her life.  I don't have time to research the rules on when a gift is completed, but you should do it because maybe you can use DOD FMV after all.  

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