112 T.C. No. 4
UNITED STATES TAX COURT
ESTATE OF HARRIETT R. MELLINGER, DECEASED,
HUGH V. HUNTER AND WELLS FARGO BANK, CO-EXECUTORS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6663-97. Filed January 26, 1999.
P died owning 2,460,580 shares of stock that were
held in her revocable trust. The stock was included in
her estate pursuant to sec. 2033, I.R.C. Also included
in her estate, pursuant to sec. 2044, I.R.C., were
2,460,580 shares of the same stock held in a QTIP trust
established by decedent's predeceased spouse. Held:
The shares of stock should not merge or be aggregated
for Federal estate tax valuation purposes.
Robert B. Martin, Jr., for petitioner.
Donna F. Herbert and Mark A. Weiner, for respondent.
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