- 29 - 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.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011