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of all property available for distribution in satisfaction
of this gift and bequest. [Emphasis added.]
On June 2, 1989, Frances Nix (the surviving spouse) executed
a partial disclaimer and renunciation of her interest in certain
property that passed to her under the will. The description and
value of the properties disclaimed by the surviving spouse are as
follows:
Office storage and carpet $25,150
Pipe storage yard 300
Working oil and gas interests 107,779
Oil and gas royalty interest 142,742
Nonproducing mineral properties 60,082
Nonproducing federal leases 25,372
Nonproducing state leases 9,498
Surface lands 23,748
Total 394,671
The value of the gross estate as of the date of decedent's
death was $1,594,496. Due to a taxable gift made by decedent
prior to his death, the unified credit available to decedent’s
estate as of the date of decedent's death was $192,300 instead of
$192,800, as provided by section 2010(a). The dollar equivalent
of the $192,300 unified credit was $598,649. Deductions fixed as
of the date of decedent's death and reported on Schedules J and K
of decedent's estate tax return were $163,304 and $1,182,
respectively.3 The State death tax credit available to
decedent's estate is $15,636, and the dollar equivalent of the
3 Respondent concedes that other deductions will be allowed to
petitioner for reasonable administrative expenses incurred in
connection with the trial of the case and expenses pursuant to
N.M. Stat. Ann. sec. 45-3-916 B. (Michie 1993 Repl.).
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