- 3 -
(2) whether decedent's husband inherited an interest in the
stock that would qualify for the marital deduction under section
2056(a)2 and, if so, the value of that interest; and
(3) whether decedent's cancellation of her daughter's debt
to her resulted in a gift to her daughter.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, the legal residence of the executrix was in New
Jersey.
Decedent and Dowell Insurance Agency, Inc.
Decedent purchased 100 percent of the agency in 1975.
Before decedent's death, she was president and treasurer of the
agency, and Patricia Low was secretary of the agency. The
revenues of the agency were derived mostly from the sale of
commercial insurance policies to contractors or manufacturing
facilities. Both decedent and Patricia Low sold these policies.
Decedent built up the agency for 15 years before she died.
Decedent thought the agency was worth about $1 million when her
will was written in 1988.
2 Section references are to the Internal Revenue Code in
effect at the date of decedent's death, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011