Estate of Lloyd P. Cavett - Page 2




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                    4.  Held, further, all of the value of the                        
               residence is includable in the gross estate, but no                    
               portion is includable as an “adjusted taxable gift”.                   
                    5.  Held, further, no deduction is allowed for the                
               bequests to the Masonic and fraternal organizations,                   
               since petitioner has failed to prove the exclusive                     
               charitable purpose of those bequests.                                  


               Kyle C. Brooks, Mark A. Denny, Richard D. Lameier, and                 
          James H. Stethem, for petitioners.                                          
          John E. Budde and John A. Freeman, for respondent.                          


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               HALPERN, Judge:  Respondent has determined deficiencies in             
          both Federal estate and gift tax liabilities.  Those deficiencies           
          are a gross deficiency in estate tax of $213,8451 and the                   
          following amounts of gift taxes:                                            
               Taxable (Calendar)                                                     
                         Year                          Amount                         
                         1964                          $298                           
                    1965                               453                            
                         1966                          731                            
                         1967                     1,370                               
                         1968                           1,484                         
                         1969                             668                         
                         1970                          707                            
                         1971                           1,257                         
                         1972                             970                         

               1    Respondent’s notice of deficiency provides for an                 
          additional State death tax credit “not exceeding $62,318.00" for            
          a “Net Deficiency Determined” of $157,527.  We assume that this             
          computation refers to the additional State death tax that would             
          accrue if we fully sustain respondent’s determination of a                  
          deficiency in estate tax liability.  Apparently, the computation            
          presents no issue for our determination.                                    





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