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Harvey R. Poe, for petitioner.
Frank A. Racaniello, for respondent.
OPINION
LARO, Judge: The parties submitted this case to the Court
without trial. Rule 122. The Estate of Rose D'Ambrosio,
Deceased (hereinafter Decedent's estate), Vita D'Ambrosio,
Executrix (hereinafter the executrix), petitioned the Court to
redetermine respondent's determination of an $842,391 deficiency
in the Federal estate tax of Decedent's estate. We must decide
whether Decedent's gross estate for Federal estate tax purposes
includes the value of 470 shares of preferred stock in which
Decedent retained an income interest for her life, after she
transferred the remainder interest in the stock for its fair
market value. We hold that Decedent's gross estate includes the
date-of-death value of the stock, reduced by the value of the
consideration she received in return for the remainder interest.
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the date of Decedent's death.
Rule references are to the Tax Court Rules of Practice and
Procedure.
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