- 2 - deduction under section 2055(a);1 and (2) whether expenses paid by petitioner in the operation of decedent's cattle ranch are deductible under section 2053 as administration expenses. We hold that petitioner's transfer does not qualify for the charitable deduction and that the expenses of operation of the cattle ranch are deductible as administration expenses. FINDINGS OF FACT Some of the facts have been stipulated and are incorporated herein by this reference. Edna Pearce Lockett (decedent) died testate on May 17, 1991, and was a resident of Florida at the time of her death. David Lanier (Mr. Lanier), the personal representative of decedent's estate, resided and practiced law in Florida at the time of filing the petition. Decedent died without issue, survived by her nephew Leland Pearce (Mr. Pearce) and by three nieces, Ruth Pearce Fulton, Patricia Pearce Durrance, and Clara Evelyn Pearce Johnson. During her lifetime, decedent served in the Florida Legislature and owned and managed a cattle ranch. 1. The Estate In February 1992, petitioner filed a Federal estate tax return, reporting a gross estate of $9,297,421. The bulk of 1 All section references are to the Internal Revenue Code as 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
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