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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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