- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011