- 2 - 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.Page: Previous 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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