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dispute as to any material facts. Hearing and argument of the
motions was held on April 22, 1996, in Memphis, Tennessee.
Charles Baxter Southern, Sr. (decedent), died on March 14,
1991, and was survived by his spouse, Dorothy I. Southern, a
daughter, two sons, and nine grandchildren. At the time of his
death, decedent was a resident of Pemiscot County, Missouri.
Probate of the will and administration of the estate was had in
the Circuit Court (Probate Division) of Pemiscot County,
Missouri. The coexecutors of decedent's estate timely filed a
Federal estate tax return. The return showed a gross estate of
$3,543,575.97 and deductions of $1,079,149, resulting in a net
estate of $2,464,426. Adjusted taxable gifts of $35,573 were
reported and when added to the estate provided a net taxable
estate of $2,499,999. The tentative tax shown was $1,025,799.51.
A unified credit of $192,800 and a credit for State death taxes
in the amount of $135,954.08 were taken, leaving a net estate tax
of $697,045.43, which was the amount paid.
Respondent determined a deficiency of $88,234 in the Federal
estate tax of the Estate of Charles Baxter Southern, Sr.,
petitioner here. Such deficiency resulted from a $166,478.26
increase in the taxable estate. That increase resulted in part
from respondent's determination that $90,000 was improperly
deducted from the gross estate as part of the computation of the
marital deduction. The second component of the increase is
$76,478.24, an amount equal to certain of the estate's
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