- 29 - decedent's death in 1993. Respondent also concedes that decedent received $14,303 of this income as distributions from Garry's estate, and that Garry's estate expended $72,266 on expenses related to the production of this income. As a result of these concessions, respondent now contends that during 1979-93, decedent became entitled to $913,200 of the investment income of Garry's estate, which was neither distributed to decedent nor spent on the costs of earning that income. Respondent further contends that decedent permitted the children to enjoy the economic benefit of this $913,200, and thereby made aggregate taxable gifts to the children of that amount, also during 1979-93. The evidence sustains respondent's first contention (and we have so found). During 1979-93, decedent became entitled to $913,200 of the investment income of Garry's estate, which was neither distributed to decedent nor spent to produce that income. We now consider whether decedent made taxable gifts of all or part of that $913,200 to her children, as respondent further contends. A. Relevance of Decedent's Taxable Gifts to This Estate Tax Case Section 2001(a) imposes the Federal estate tax on the transfer of the "taxable estate" of every decedent who is a citizen or resident of the United States. Under certainPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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