Estate of Bessie I. Mueller, Deceased, John S. Mueller, Personal Representative - Page 29

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            claimed on the Federal estate tax return, respondent determined a                          
            deficiency of $1,985,624 in petitioner’s Federal estate tax.                               
            Petitioner petitioned this Court for a redetermination.                                    
                  In Mueller I, we found that the date-of-death value of the                           
            shares was $15,170,800, or $1,700 per share.  Our revaluation,                             
            standing alone, would result in an increase in Federal estate tax                          
            of $957,099, computed at the top marginal estate tax rate of 55                            
            percent in effect during 1986, prior to allowance of additional                            
            credits for State death taxes and for tax on prior transfers and                           
            a small reduction in the unified credit.                                                   
                  The Administration Trust is a revocable inter vivos trust                            
            established by decedent3 and is the residuary legatee of her                               
            probate estate.4  Under Article IV of the trust instrument, the                            
            Administration Trust is obliged to pay all death taxes, but                                
            Article III of the second codicil to decedent's will directs that                          
            all death taxes be first paid out of decedent's probate estate as                          


                  3The beneficiaries of the Trust are three subtrusts:  The                            
            first for the benefit of decedent’s niece Mary M. Hanson and                               
            decedent’s friend Jean Ehlinger and the two other subtrusts known                          
            as the Bessie I. Mueller Irrevocable Trusts A and B for the                                
            benefit of decedent’s grandchildren:  Justin R. Mueller, Anne E.                           
            Mueller, and Heidi M. Mueller.                                                             
                  4The noncharitable legatees of decedent’s estate are                                 
            decedent’s sons John S. Mueller and James F. Mueller; decedent’s                           
            two granddaughters by son John, Anne E. Mueller and Heidi M.                               
            Mueller; Bessie I. Mueller Irrevocable Trusts A (f/b/o grandson                            
            Justin R. Mueller) and B (f/b/o granddaughters Anne E. Mueller                             
            and Heidi M. Mueller); the Bessie I. Mueller Administration                                
            Trust; decedent’s niece Mary M. Hanson; friend Jean M. Ehlinger;                           
            decedent’s nephew William E. Pearson; and friend Harriet Suggs.                            




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Last modified: May 25, 2011