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After concessions, the sole issue for decision is whether
certain trade fixtures were includable in decedent's gross
estate.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, supplemental stipulation of facts,
stipulation of settled issues, and attached exhibits are
incorporated herein by this reference.
James G. Frazier (decedent) died on March 20, 1993. At the
time of his death, decedent resided in Waterford, California.
On or about June 22, 1994, petitioner James G. Frazier, Jr.,
as executor, filed decedent's estate tax return. At the time the
petition was filed, petitioner resided in Stanislaus County,
California.
In 1981, decedent incorporated Frazier Nut Farms, Inc.
(FNF). FNF conducted an almond and walnut processing, packaging,
marketing, sales, and shipping business.
On January 1, 1983, decedent, as landlord, and FNF, as
tenant, executed a lease for a 5-acre tract of land located in
Waterford, California (the land). Under the terms of the lease,
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at the date of decedent's
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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