T.C. Memo. 2000-91
UNITED STATES TAX COURT
ESTATE OF LLOYD P. CAVETT, DECEASED, LLOYD PETERSON
AND KYLE C. BROOKS, CO-EXECUTORS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 21702-96, 21735-96. Filed March 15, 2000.
R determined deficiencies in both estate and gift
taxes. Ps claim overpayments of estate tax. We must
determine whether (1) Ps are estopped from denying that
certain inter vivos payments to decedent’s longtime
companion were gifts, (2) assuming there is no
estoppel, the payments were gifts or payments for
services, (3) a bequest to that companion is a
deductible claim against the estate, (4) only one-half
the value of decedent’s residence is includable in the
gross estate, and (5) certain bequests to Masonic and
fraternal organizations are deductible for estate tax
purposes.
1. Held: Ps are not estopped from denying the
gift character of the inter vivos payments.
2. Held, further, the inter vivos payments were
gifts.
3. Held, further, the bequest is not a deductible
claim against the estate.
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