- 24 - that the Bard property was decedent’s separate property at the time of his death. E. Conclusion The New Mexico ranch was decedent's separate property. Petitioner has not persuaded us that the character of either that property or the successor properties changed during decedent's lifetime. Therefore, decedent's interest in the Bard property was decedent's separate property on the date of his death, and therefore the value of that property is includable in his gross estate. Petitioner received a one-third interest in that property under the intestate succession laws of the State of California, and only the value of that one-third interest is deductible in computing the taxable estate. Decision will be entered under Rule 155.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Last modified: May 25, 2011