115 T.C. No. 13 UNITED STATES TAX COURT ESTATE OF JUDITH U. HARRISON, DECEASED, RICHARD J. TEJEDA, EXECUTOR, AND ESTATE OF KENNETH R. HARRISON, DECEASED, RICHARD J. TEJEDA, EXECUTOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16018-98. Filed August 22, 2000. H and W boarded their private aircraft in July of 1993 but never arrived at their destination. Subsequently, probate orders were entered presuming identical April 1, 1994, dates of death and finding it more probable than not that the airplane crashed en route. The will of each spouse presumed survival by the other in circumstances where order of death was unknown and transferred a life estate to such surviving spouse. For estate tax purposes, the transferred life estates were valued on the basis of actuarial tables, and each estate took a credit for tax on prior transfers pursuant to sec. 2013, I.R.C. R disallowed these credits on the grounds that, under recognized valuation principles, the life estates were not to be valued by resort to actuarial tables but, rather, must be accorded no value. Held: The reciprocal life estates at issue are not appropriately valued utilizing actuarial tables, must bePage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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