-6-
pursuant to which: (1) Ms. Barnett agreed not to seek probate of
the August 5 codicil; (2) Ms. Barnett would be paid $175,000; (3)
Ms. Barnett surrendered entitlement to any legacy in trust or
otherwise contained in the will or codicil; and (4) Ms. Barnett and
Hilda agreed to the division of certain personal property owned by
decedent which was in the possession of Ms. Barnett at the time of
decedent's death.
Decedent's will and the August 18 codicil were admitted to
probate by the Surrogate's Court of Nassau County, New York.
The estate tax return was filed on January 2, 1990. It
reported a total gross estate of $8,495,460. The estate claimed a
marital deduction of $7,305,191, which consisted of $3,965,959 in
property interests not subject to a QTIP election and $3,339,231 in
property interests subject to a QTIP election.1 Respondent, after
making numerous adjustments that increased decedent's gross estate,
disallowed $1,701,372 of the claimed marital deduction.
1 The $1 mathematical difference is due to rounding.
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