4 Edward died on June 19, 1989, less than 3 years after the transfer on October 31, 1986. The estate tax return for his estate reported adjusted taxable gifts of $51,372.50, which is $71,372.50 less two $10,000 exclusions pursuant to section 2503(b), representing the life estates created in Edward F. and Frederick. Petitioner did not include the gift of real property made by decedent on October 31, 1986, as an adjusted taxable gift on decedent's estate tax return. In the notice of deficiency, respondent determined that the estate must include $51,372.50 as adjusted taxable gifts, and that there were no further exclusions available for the grandchildren, as those interests were merely future interests. A tax is imposed upon the transfer of the taxable estate of a decedent who is a citizen or resident of the United States. Sec. 2001(a). The tax is computed first by determining a tentative tax on the sum of the taxable estate and the adjusted taxable gifts, and then reducing that tentative tax by the amount of gift tax that would have been payable on those gifts, using the rates in effect at the decedent's death. Sec. 2001(b). The term "adjusted taxable gifts" for purposes of this subsection means all taxable gifts made by decedent after December 31, 1976, other than gifts that are includable in the gross estate of decedent. Taxable gifts are the total amount of gifts made during the calendar year, less any available deductions orPage: Previous 1 2 3 4 5 6 7 8 9 Next
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