- 8 - marital deduction ultimately allowed to Garry's estate, was $2,154,781. As filed with respondent, petitioner's estate tax return reported a gross estate of $1,107,141, a taxable estate of $272,756, and adjusted taxable gifts of $313. Garry's will left the residue of his estate to the children. His will specifically provided that all Garry's debts and expenses of estate administration and all inheritance and other transfer taxes were to be paid from the residuary estate, without apportionment. Garry's estate ultimately paid respondent and the State of Indiana a total of over $1 million on account of estate and inheritance taxes. The parties agree that pursuant to Garry's will these taxes (and all administration expenses) were the obligation of the children, to be paid out of their shares of the estate. During the 14-year period between Garry's death and decedent's death (i.e., from 1979 to 1993) Garry's estate was neither wound up nor terminated. Instead, it was administered as an unsupervised estate; decedent was the personal representative. Garry's estate therefore continued to hold substantial assets and to receive substantial amounts of income during this period.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