109 T.C. No. 15
UNITED STATES TAX COURT
ESTATE OF MILDRED GERALDINE LETTS, DECEASED, JAMES P.
LETTS III AND JOANNE L. MAGBEE, COEXECUTORS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8539-95. Filed November 24, 1997.
Decedent's (D) husband (H) died in 1985, and D
died in 1991. They were survived by two children,
James P. Letts III and JoAnne Magbee. James P. Letts
III was executor of both of their estates and signed
both estate tax returns. D was also a coexecutor of
H's estate, and JoAnne Magbee was a coexecutor of H's
and D's estates. The beneficiaries of H's will were D,
James P. Letts III, and JoAnne Magbee. The
beneficiaries of D's will were James P. Letts III and
JoAnne Magbee.
In his will, H left certain property to D. H's
estate claimed a marital deduction for the value of the
property. H's estate elected not to treat D's interest
as qualified terminable interest property (QTIP). H's
estate was entitled to claim the marital deduction for
the property only if D's interest in the property was
not a terminable interest.
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