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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