Estate of Arthur C. Edwards, Deceased, Kenneth Edwards, Edward Edwards and James Edwards, As Trustees of the Arthur C. Edwards Settlement Trust, Personal Representative - Page 2

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          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.                                                     




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