2
All statutory references are to the Internal Revenue Code in
effect as of the date of decedent's death, and all Rule
references are to the Tax Court Rules of Practice and Procedure,
except as otherwise noted. After the settlement of other issues,
there remains for decision:
(1) Whether a gift in 1986 of an interest in real property
held by decedent as a tenant by the entireties with her spouse
was an "adjusted taxable gift" for purposes of computing the
estate tax of the decedent. We hold that it is.
(2) Whether there should be allowed additional annual donee
exclusions under section 2503(b), above those allowed by
respondent, in respect of four donated remainder interests. We
hold that no additional exclusions are available for such
interests.
Petitioner is the Estate of Anne F. Greco (decedent), who
died on January 14, 1991. At the time of her death, decedent
resided in Falls Church, Virginia. Edward F. Greco (Edward F.)
and Frederick D. Greco (Frederick), her two sons, were appointed
coadministrators of her estate. The principal office of the
estate was located in McLean, Virginia, when the petition was
filed. Petitioner timely filed a Federal estate tax return on
September 13, 1991. Respondent issued a notice of deficiency to
the estate on August 15, 1994. Frederick filed a petition with
this Court on behalf of the estate on November 10, 1994.
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