- 18 - and as transferees of the assets of decedent's estate. Respondent also issued notices of deficiency to decedent's other daughters, Celeste Schettig and Honore O'Brien, as transferees of assets from the estate of Honore, but limited their liability to $169,404 each. In addition, respondent issued notices of deficiency to the four residuary trusts established in Mr. de St. Aubin's will as transferees of assets of the estate of decedent. The notices limited the trusts' liability to $8,595,606.80 each. The issue of transferee liability arose by reason of the transfer of assets to petitioners that respondent contends are includable in decedent's gross estate. The above-named petitioners filed timely petitions with this Court. They dispute the entire amounts of the deficiencies. OPINION Petitioners request the following three holdings in their motion for partial summary judgment: 1. Neither Honore V. de St. Aubin ("Honore") nor her Estate had a claim to "delayed income" under the New York Principal and Income Act (Estates, Powers and Trust Law ["EPTL"] �11-2.1) at the date of Honore's death with respect to the shares of stock in Modern Globe, Inc. held by the estate of her husband, Ovide de St. Aubin ("Ovide");Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011