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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011