Estate of Edna Pearce Lockett Deceased, David F. Lanier, Personal Representative - Page 2

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          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.            


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