- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011