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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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