Estate of Sarah M. Davenport, Deceased, Richard Davenport, Executor - Page 1

                                 T.C. Memo. 2006-215                                  


                               UNITED STATES TAX COURT                                


             ESTATE OF SARAH M. DAVENPORT, DECEASED, RICHARD DAVENPORT,               
                               EXECUTOR, Petitioner v.                                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16060-04.               Filed October 5, 2006.              


                    D died on Oct. 31, 2000, and a Federal estate tax                 
               return was thereafter filed on behalf of her estate.                   
                    Held:  Two annuities payable under a settlement                   
               agreement are includable in the gross estate pursuant                  
               to sec. 2033, I.R.C.                                                   
                    Held, further, for purposes of inclusion in the                   
               gross estate, the annuities are to be valued under sec.                
               7520, I.R.C., in accordance with the actuarial                         
               valuation methodology of sec. 20.2031-7(d), Estate Tax                 
               Regs.                                                                  
                    Held, further, under the circumstances present in                 
               this case, expenditures incurred for a funeral luncheon                
               are not properly deductible as funeral expenses under                  
               sec. 2053(a)(1), I.R.C.                                                







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