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market mutual funds, a money market bank account, a checking bank
account, jewelry, and household effects and furniture.
On or about January 4, 1995, Mr. Grant and Ms. Adams, as
personal representatives of the estate, filed Form 706, United
States Estate (and Generation-Skipping Transfer) Tax Return
(estate tax return), which showed estate tax due of $60,118. In
determining that amount of estate tax due, the estate tax return
claimed a credit for state death taxes of $23,911. The Register
of Wills, Montgomery County, Maryland, had determined that
Maryland inheritance tax of $8,663.30 was due on $866,330 of the
decedent’s nonprobate assets consisting of $405,000 of real
property and $461,330 of personal property.
The estate tax return reported as part of decedent’s gross
estate, inter alia, the following assets: decedent’s residence
valued as of the date of decedent’s death pursuant to an ap-
praisal at $405,000; stocks, including dividends, valued at
$263,830; five money market mutual funds with total funds,
including dividends, of $121,603; a checking bank account with
funds of $31,274; a money market bank account with funds of
$17,879; and a joint money market mutual fund with funds of
$7,228. According to Schedule G of the estate tax return, the
value of the decedent’s nonprobate property was $865,480. That
return also indicated that decedent did not have any debts and
that there were no mortgages or liens on any property which she
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