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Unless otherwise indicated, section references are to the
Internal Revenue Code applicable to the year in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations and the exhibits attached thereto are
incorporated herein by this reference. Raymond Geftman
(Decedent), petitioner's father, died on February 28, 1983. He
resided in Fort Lauderdale, Florida, at the time of his death.
Petitioner resided in Gladwyne, Pennsylvania, when he filed his
petition. He became 16 years old during 1985.
Three testamentary trusts were established pursuant to
Decedent's last will and testament (Will): Trust A, Trust B, and
Trust C. Trust A was funded with 40 percent of Decedent's
residuary estate. Trust B and Trust C were each funded with 30
percent of Decedent's residuary estate. The estate, trusts, and
petitioner all had different taxable years: The estate had a
fiscal year ending March 31, each of the trusts had a fiscal year
ending February 28, and petitioner was on the calendar year.
Pursuant to the Will, five individuals appointed as co-personal
representatives of the estate were also appointed as cotrustees
of the testamentary trusts.2
2 In addition to those five individuals, the Will appointed
(continued...)
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