Estate of Albert Fratini, Deceased, Marion Friedeberg, Personal Representative - Page 2

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          held in the joint name of decedent and Ms. Friedeberg on the date           
          of decedent's death; (2) whether decedent's estate is entitled to           
          reduce the amount required to be included under section 20401 by            
          claimed fractional interest discounts applied to decedent's                 
          interest in parcels of real property owned in joint tenancy with            
          Ms. Friedeberg on his date of death; and (3) whether pursuant to            
          section 2053, the estate is entitled to a deduction for more than           
          50 percent of the mortgage debt outstanding on jointly owned real           
          properties includable in the estate.                                        

                                  FINDINGS OF FACT                                    

               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and supplemental stipulation of facts              
          are incorporated herein by this reference.                                  
               Albert Fratini (decedent), who was a resident of San                   
          Francisco, California, died on June 2, 1992.  Decedent was not              
          married when he died.  For 18 years preceding his death, decedent           
          continuously lived with Marion Friedeberg.  Ms. Friedeberg is the           
          estate's personal representative and the sole beneficiary under             
          decedent's holographic will.  At the time she filed the petition            
          herein, Ms. Friedeberg resided in San Francisco, California.                

               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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