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F. Decedent Gave Her Investment Income to Children
As Asserted by Respondent on Brief, Except to
Limited Extent Income Was Used To Pay Decedent's
Share of Expenses of Family Farm ......... 60
II. Is Petitioner Entitled To Deduct a Portion of
Land Bank Loan as Unpaid Mortgage? .......... 64
A. Value of Security Included in Decedent's Estate .. 65
B. Uncertainty That Land Bank Loan Will Ever Be
Paid by Decedent's Estate ............ 68
1. Petitioner's Section 2053 Deduction Must
Be Reduced on Account of Decedent's
Contribution Rights ............. 68
2. The Value of Decedent's Contribution Rights
Cannot Be Determined ............ 70
3. Decedent's Status as Guarantor or
"Accommodation" Party ............ 71
C. Conclusion Re Unpaid Mortgage Deduction ...... 72
III. Unused Exclusions Available as Conceded in
Respondent's Brief; Offset and Deduction for Gift
Taxes Payable ................... 74
MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge: Respondent determined a deficiency of
$1,243,548 in the Federal estate tax of the Estate of Ona E.
Hendrickson, Donald G. Hendrickson, personal representative
(petitioner). Respondent also determined a late filing addition
to tax of $248,710 under section 6651(a)(1).1
1 All section references are to the Internal Revenue Code,
and all Rule references are to the Tax Court Rules of Practice
and Procedure, unless otherwise specified.
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Last modified: May 25, 2011