Estate of Ona E. Hendrickson - Page 3




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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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