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petitioner's Federal estate tax within the meaning of section
6212(a).1
Background
Petitioner is the Estate of Doris L. Rickman. Doris L.
Rickman (decedent) died on October 24, 1990, in Franklin,
Georgia. Decedent's husband, James R. Rickman, died on October
19, 1990, 5 days before decedent died.
Doris K. Rickman, decedent's daughter, was duly appointed
executrix of the decedent's estate under letters testamentary
issued by the clerk of the Superior Court of Macon County, North
Carolina, on October 30, 1990.2 Doris K. Rickman is also the
duly appointed executrix of the Estate of James R. Rickman. At
the time the petition herein was filed, Doris K. Rickman resided
in Franklin, North Carolina.
On or about March 22, 1991, Doris K. Rickman filed separate
Forms 709 (United States Gift Tax Return) on behalf of both James
R. Rickman (Mr. Rickman) and decedent for the taxable years
ending on the date of their deaths. Schedule A of Form 709 filed
on behalf of Mr. Rickman lists the following gifts:
1 All section references are to the Internal Revenue Code,
as amended, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
2 The record in this case indicates that Doris K. Rickman
is also known as Kaye Rickman.
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