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Additions to Tax
Deficiency Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B)
50% interest on:
$1,685,271 $84,264 $1,685,271
Unless stated otherwise, all section references are to the
Internal Revenue Code in effect for the date of the
decedent's death.
After concessions, the sole issue for decision is
whether petitioner is eligible to deduct, as an allowance
of marital deduction under section 2056(a), the value of
certain property distributed to a testamentary trust for
the benefit of the decedent's surviving spouse. This
issue turns on whether the subject property is "qualified
terminable interest property" within the meaning of section
2056(b)(7).
FINDINGS OF FACT
The parties have stipulated some of the facts that
are pertinent to this case. The stipulation of facts filed
by the parties and the exhibits attached thereto are
incorporated herein by this reference.
The decedent, Mr. Bert B. Rapp, died on February 23,
1988. He was a California resident at that time. The
executor of the decedent's estate, Mr. Richard Rapp, the
decedent's son, was also a California resident when the
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Last modified: May 25, 2011