- 3 -
1973 1,143
1975 726
1976 59
Petitioners have made two claims for refund of estate taxes in
the amounts of $212,438.06 and $80,984.70 (the first and second
claim for refund, respectively). Certain adjustments relating to
the estate tax deficiency have been settled and are no longer of
concern to us.
An issue common to these consolidated cases is whether
certain payments by Lloyd Cavett (decedent) to Rose Bell (Bell)
were gifts. In connection with that issue, we must determine
whether petitioners are collaterally estopped from denying that
those payments were gifts. Additionally, we must determine
whether: (1) Certain bequests to Bell constitute deductible
claims against the estate (the first claim for refund),
(2) petitioners are entitled to reduce the value of decedent's
residence included in the gross estate by 50 percent as a result
of respondent's inclusion of 50 percent of that residence as an
adjustable taxable gift (the second claim for refund), and
(3) petitioners are entitled to a $22,000 deduction for donations
to various Masonic and fraternal organizations.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect, with respect to the estate
tax, at the time of decedent’s death or, with respect to the gift
taxes, for the taxable year during which the particular gifts
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