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Barkat A. Khan, was a resident of the United States at the time
of his death. If decedent was a resident of the United States at
the time of his death, petitioner is subject to the Federal
estate tax imposed on the estates of U.S. residents under section
20012 and is entitled to the unified estate and gift tax credit
of $192,800 allowed under section 2010. If decedent was a
nonresident at the time of his death, petitioner is subject to
the Federal estate tax imposed on the estates of noncitizen
nonresidents under section 2101 and is entitled to a unified
credit of $13,000 under section 2102(c)(1).
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the exhibits attached
thereto are incorporated herein by this reference.
Decedent, Barkat A. Khan, died in Pakistan on February 25,
1991. Decedent's son Mohammed Aslam Khan (Aslam) is the executor
of decedent's estate and resided in Butte City, California, when
the petition was filed in this case.
Decedent was born in India in 1910. In 1947, the area of
India in which decedent lived became part of the newly formed
1(...continued)
$4,575.
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the date of decedent's
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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