Estate of Lucille R. Devlin, Deceased, C. Ronald Lambert, Executor - Page 2




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          decedent’s gross estate includes gifts that were authorized by a            
          State court order issued before decedent’s death but were made              
          after decedent's death.                                                     
               The instant case was submitted fully stipulated pursuant to            
          Rule 122.2  The facts stipulated by the parties are incorporated            
          herein by reference and are found as facts in the instant case.             
               C. Ronald Lambert is the executor of the Estate of Lucille             
          R. Devlin and the son of Lucille Devlin (decedent).  At the time            
          the petition was filed, C. Ronald Lambert resided in Columbus,              
          Nebraska.  When she died, decedent was a resident of Columbus,              
          Nebraska.                                                                   
               Decedent had another son, Randall T. Lambert, who married              
          Patricia Lambert and had three children:  Cynthia Lambert, Sandra           
          Lambert, and Randall T. Lambert, Jr.  C. Ronald Lambert married             
          Charlotte K. Lambert and had three children:  Mark Lambert,                 
          Kimberly Lambert, and Tiffanie Lambert.                                     
               On January 8, 1986, the county court of Platte County,                 
          Nebraska (county court), appointed Randall T. Lambert and C.                
          Ronald Lambert, as guardians-conservators for decedent pursuant             
          to Neb. Rev. Stat. sec. 30-2630(2) (Reissue 1995). Randall T.               
          Lambert died on April 19, 1986.  On August 28, 1986, the county             


          2    Unless otherwise indicated all section references are to the           
          Internal Revenue Code in effect at the time of decedent’s death,            
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              





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