T.C. Memo. 1998-416
UNITED STATES TAX COURT
ESTATE OF BETTY PACE MILLER, DECEASED,
JERRY D. WALKER, INDEPENDENT EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11889-97. Filed November 18, 1998.
Valentine C. Cronin and Richard Keys Disney, for petitioner.
John R. Hunter, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge: Respondent determined a deficiency of
$408,274 in the Federal estate tax of decedent's estate. After
concessions, the sole issue for decision is whether, under the
terms of decedent's will and Texas law, the surviving spouse's
portion of the residuary estate is required to bear a
proportionate share of Federal estate tax, thereby reducing the
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