Estate of Lloyd P. Cavett - Page 1

                                 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                  
                    1.  Held: Ps are not estopped from denying the                    
               gift character of the inter vivos payments.                            
                    2.  Held, further, the inter vivos payments were                  
                    3.  Held, further, the bequest is not a deductible                
               claim against the estate.                                              

Page:   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