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the Probate Inventory and caused it to be filed with the local
probate court, which was done in May 1993. The Probate Inventory
had been prepared by Messrs. Meyer and Kadish with the assistance
of decedent and listed the assets included in Mrs. Chamberlain's
probate estate as valued on December 7, 1992, her date of death.
Total values of the assets listed were as follows:
Cash and equivalents $248,195.87
Bonds 157,543.45
Stocks 69,581.63
Total inventory 475,320.95
The Probate Inventory filed with the probate court did not refer
to any disclaimer of any assets by decedent.
On September 30, 1993, a Federal estate tax return, Form
706, was filed with the Internal Revenue Service by decedent on
behalf of the Estate of Mrs. Chamberlain.5 On the Form 706, Line
1, decedent reported a gross estate of $883,006, including
$385,319 of jointly owned property, and on Line 2, total
allowable deductions of $390,245, which included a marital
deduction of $385,319. Decedent reported a taxable estate of
$492,761 and calculated a tentative tax of $153,339 and an
allowable unified credit of $192,800. Subtraction of the
allowable unified credit from the tentative tax amount produced
5 The Form 706 was due Sept. 7, 1993. See sec. 20.6075-1,
Estate Tax Regs. No extension request was filed, presumably
because it was clear that Mrs. Chamberlain's estate would not be
taxable because of the availability of the marital deduction and
the unified credit.
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