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an amount less than zero; accordingly, decedent reported zero
estate tax liability on Line 27 of the Form 706 because the
entire tentative tax had been absorbed by the unified credit.
In April 1994, subsequent to the death of decedent in
February 1994, Mr. Meyer met in chambers with Judge Lee Johnson
of the Oregon Circuit Court for Multnomah County, Probate
Department, to discuss a proposed order of distribution for
Mrs. Chamberlain's estate different from that provided by her
will. Mrs. Chamberlain's will provided that the residue of her
estate was to pass to decedent or, to the extent disclaimed, the
Family Residuary Trust. Because decedent had died, Messrs. Meyer
and Kadish considered it unnecessary to distribute the assets to
a trust and then redistribute them from the trust to Dale. On
April 8, 1994, the Probate Department of the Oregon Circuit Court
for Multnomah County, in an order signed by Judge Johnson,
authorized an order of distribution for Mrs. Chamberlain's estate
under which all remaining assets of the estate, after payment of
expenses, were to be distributed to Dale.
On November 21, 1994, a Federal estate tax return, Form 706,
was timely filed with the Internal Revenue Service by petitioner,
the estate of decedent. On the Form 706, line 1, petitioner
reported a gross estate of $1,104,352. On part 5, of the Form
706, the recapitulation of the gross estate showed the following
date of death value amounts:
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