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decedent’s death, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
After settlement of some issues, the issue for decision is
whether, in the computation of petitioner’s Federal estate tax,
decedent’s inter vivos transfer of property to an irrevocable
trust is eligible under section 2503(b) for the annual gift tax
exclusion with respect to each of 16 contingent beneficiaries of
the trust.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner is the Estate of Lieselotte Kohlsaat, deceased, Peter
Kohlsaat, coexecutor. Decedent died a resident of New Jersey.
When the petition was filed, Peter Kohlsaat resided in Cresskill,
New Jersey.
On March 27, 1990, decedent formed the Lieselotte Kohlsaat
Family Trust as an irrevocable trust (the trust) and transferred
to the trust a commercial building owned by decedent and managed
for many years by various Kohlsaat family members. At the time
of decedent’s transfer of the building to the trust, the building
was valued at $155,000. Thereafter, no other transfers were made
to the trust.
Under provisions of the trust, Beatrice Reinecke (Beatrice)
and Peter Kohlsaat (Peter), decedent’s two adult children, were
designated as cotrustees and primary beneficiaries of the trust.
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Last modified: May 25, 2011