- 53 -
exclude annually $10,000 of the total gifts which he made to each
person. See sec. 2503(b).
We hold that the decedent's transfers to or on behalf of
Ms. Wong, Mr. Skauronski, and Mr. Pasko are includable in the
decedent's estate tax computation as taxable gifts. After
applying the annual exclusion for each donee, the decedent's
adjusted taxable gifts for 1990 are increased by $267,447,
$15,000, and $15,000, respectively, or a total of $297,447.
c. The $258,825 Claim Against Superior
Respondent determined that the estate had a $258,825 claim
against Superior, and that this claim was miscellaneous property
of the estate. The estate valued this claim at zero on the
estate tax return, identifying it as a claim against Superior for
the release of coins assigned to Superior. The return noted that
the probability and amount of any collection of this claim was
unknown.
We hold for the estate on this issue. The value of this
claim was zero on the applicable valuation date, as evidenced by
the fact that the estate received only its coins back in
settlement of its dispute with Superior. The value of the
returned coins was included in the gross estate, as discussed
above.
5. Ms. Trompeter's Claim
Page: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 NextLast modified: May 25, 2011