- 2 - response in opposition to petitioner's motion. Both petitioner and respondent submitted memoranda in support of their positions. Respondent determined a deficiency in petitioner's Federal estate tax of $14,107,060. The deficiency was due primarily to respondent's increased valuation of decedent's stock in his closely held corporations, as well as respondent's disallowance of certain deductions for claims against the estate. The parties have resolved the valuation issues. The disallowed deductions relate to various claims on dece- dent's closely held stock. Specifically, Ann Goss, decedent's former wife, holds a claim to the income from the stock for her life, and his three children hold a claim to the remainder interest in the stock. Respondent has conceded that the estate is entitled to a deduction for Ann Goss' interest in the stock. Therefore, the issue for decision is whether petitioner is entitled to deduct the value of the decedent's children's remainder interest in the stock as a claim against the estate under section 2053(a)(3). We may grant a motion for summary judgment under Rule 121 "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits, if any, show that there is no genuine issue as to any 1(...continued) death, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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