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qualified income interest for life and for which a deduction was
allowed under section 2056(b)(7)1 to the estate of Andrew J.
Soberdash must be included in decedent's gross estate pursuant to
section 2044; (2) whether the gross estate should be increased by
$91,010.91 to include cash equivalents which are not reported on
petitioner's Federal estate tax return; and (3) whether the gross
estate should be increased by $15,927.26 to include income
accrued at decedent's death.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
reference. Decedent died on March 10, 1992, while domiciled in
Fayette County, Pennsylvania. Her estate is being administered
in the Court of Common Pleas of Fayette County. The
coexecutrices of the estate are Wilma Porada and Mary Ann Lacek.
At the time of filing the petition, Wilma Porada resided in
Parma, Ohio, and Mary Ann Lacek resided in North Royalton, Ohio.
Decedent's husband, Andrew J. Soberdash (hereinafter
Andrew), died on November 27, 1982. At the time of his death,
they had been married for 48 years.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect as of the date of decedent's
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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