Estate of Vesta K. Alward - Page 6




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          directors of the association, two would be members of the Emerson           
          Baptist Church and two would be members of the Emerson Christian            
          Church.                                                                     
               The Emerson Baptist Church is located on land that has the             
          following legal description:                                                

               All of Lots Five (5), Six (6), Seven (7) and Eight (8),                
               Block Nineteen (19), Emerson, Marion County, Missouri.                 

               The association land has the following legal description:              

               All of Block Seven (7) and the West Half of Jefferson                  
               Street East of said Block Seven (7), and All of Lots                   
               One (1), Two (2), Three (3), Four (4), Five (5) and Six                
               (6), Block Ten (10), all in Emerson, Marion County,                    
               Missouri.                                                              
               The parcels of real property owned by the Emerson Baptist              
          Church are separate and distinct from the parcels of real                   
          property owned by the association.  There is no common ownership.           
                                       OPINION                                        
               The Commissioner's determinations are presumptively correct,           
          and the taxpayer bears the burden of proving otherwise.  See Rule           
          142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).                       
               Section 2055 provides in relevant part:                                
                    (a) In General.--For purposes of the tax imposed                  
               by section 2001, the value of the taxable estate shall                 
               be determined by deducting from the value of the gross                 
               estate the amount of all bequests, legacies, devises,                  
               or transfers--                                                         







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Last modified: May 25, 2011