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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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