- 2 - required by sec. 2056(b)(5), I.R.C., and the regulations thereunder. Thomas J. Shroyer, Robert B. Firing, Nicky R. Hay, and Steven Z. Kaplan,1 for petitioner. John C. Schmittdiel, for respondent. OPINION LARO, Judge: This case was submitted to the Court without trial. See Rule 122. The Estate of Dorothy M. Walsh, Deceased, Charles E. Walsh, Personal Representative, petitioned the Court to redetermine respondent's determination of a $291,651 deficiency in Federal estate tax. We must decide whether certain property is eligible for the marital deduction under section 2056(a). We hold it is not. Unless otherwise indicated, section references are to the applicable provisions of the Internal Revenue Code. Rule references are to the Tax Court Rules of Practice and Procedure. Decedent references are to Dorothy M. Walsh. Estate references are to the decedent's estate. Background All facts have been stipulated and are so found. The stipulation of facts and the exhibits submitted therewith are incorporated herein by this reference. The decedent was a U.S. 1 Mr. Kaplan, who prepared the subject petition, withdrew as counsel of record on Mar. 4, 1998.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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