- 16 - significantly more Federal estate taxes than the estate reported on its return and paid. Petitioners contend that an audit was nearly certain because the gross estate was large (almost $23 million) and respondent could dispute the fair market value of Ripplestone. Petitioners contend that Trust B needed to keep Ripplestone because it had only $220,822 in assets other than Ripplestone after the estate filed its estate tax return, and that $220,822 was not an adequate reserve for its potential tax liability. Respondent points out that Trust B would have had more than $220,833 in assets other than Ripplestone if Trust B had not distributed some of its interest and dividend income to Trust C. Respondent contends that Trust B was not required to distribute income to Trust C or to keep Ripplestone as a reserve against potential tax liability. D. Whether It Was Necessary for Trust B to Hold Ripplestone After March 16, 1990, and Sell It To Ensure That It Could Pay Petitioner's Estate Tax Liability 1. Whether the Trust Agreement Required Trust B To Distribute Interest and Dividend Income to Trust C Under the trust agreement, Trust B's interest and dividend income, Ripplestone, and all of the other Trust B assets which decedent did not appoint to Trust A were treated the same.6 The 6 The trust agreement provided that when decedent dies, the (continued...)Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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