Jewell E. Gray, Donor, Deceased and Estate of Jewell E. Gray, Deceased, Jewell Mae Detjen, Personal Representative, et al. - Page 10

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          1986 gift tax return that the value of the transfer was $456,705.           
          She claimed a marital deduction of $456,705 for the gift under              
          section 2523.                                                               
               The assets in irrevocable trust #1 were transferred to                 
          irrevocable trust #2 after Clifford Gray died on January 5, 1988.           
               3.   Irrevocable Trust #2                                              
               The trust agreements provided that the income and principal            
          of irrevocable trust #2 was to be accumulated during decedent's             
          lifetime.  Decedent's granddaughter and great-grandchildren were            
          the remainder beneficiaries of irrevocable trust #2.                        
          Irrevocable trust #2 transferred 109 shares of Beth W. Corp.                
          stock to Beth W. Corp. on March 19, 1988, and 75 shares on July             
          31, 1989.  Irrevocable trust #2 treated those transfers as                  
          redemptions and reported the amounts received in exchange as                
          dividends on its income tax returns.  The redemptions were                  
          recorded on duly executed stock certificates.                               
               4.   Irrevocable Trust #3                                              
               Decedent created and transferred 1,004 shares of Beth W.               
          Corp. stock to irrevocable trust #3 on March 19, 1987.  The trust           
          agreement for irrevocable trust #3 required the trustees to                 
          distribute all principal and accumulated income to Pollett when             
          decedent died.  Irrevocable trust #3 did not grant to any                   
          beneficiary a power to demand immediate possession of any part of           
          the corpus.  Decedent reported on her 1987 gift tax return that             





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