Estate of Anne F. Greco, Deceased, Frederick D. Greco, Co-Administrator - Page 2

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               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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