- 2 -
amounts claimed under section 2053.1 We hold that it is to the
extent stated herein.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, P. Walker Grant, Jr.
(Mr. Grant), the son of decedent and a personal representative of
the estate, resided in Shelburne, Vermont.2
On October 1, 1991, Ms. Grant, who was residing and domi-
ciled in Montgomery County, Maryland, executed a declaration of
trust (declaration of trust) under which she placed most of her
real and personal property into a revocable trust known as the
“CONSTANCE R. GRANT REVOCABLE TRUST” (Trust). The declaration of
trust provided in pertinent part:
2. Trust Estate. I hereby transfer, assign,
convey and quit claim unto myself, as Trustee, and unto
my successors in trust all of the property enumerated
in Schedule A hereto attached, to have and to hold such
property, and any other property which may be added to
the Trust Estate pursuant to the provisions hereof, all
of which property is hereinafter collectively referred
to as the “Trust Estate”.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect on the date of the death of
Constance R. Grant (decedent or Ms. Grant). All Rule references
are to the Tax Court Rules of Practice and Procedure.
2Kathryn Lynn Grant Adams (Ms. Adams), the only other child
of decedent, also served as a personal representative of the
estate. The record does not disclose where Ms. Adams resided at
the time the petition was filed in this case.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011