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deemed without value for estate tax purposes, and,
therefore, will not support allowance of credits for tax on
prior transfers under sec. 2013, I.R.C.
Michael Antin, for petitioners.
Donna F. Herbert, for respondent.
OPINION
NIMS, Judge: Respondent determined a deficiency in Federal
estate tax with respect to the Estate of Judith U. Harrison, in
the amount of $16,457, and a deficiency in Federal estate tax
with respect to the Estate of Kenneth R. Harrison, in the amount
of $16,457. After concessions, the sole issue for decision is
whether the estates of Judith U. Harrison and Kenneth R. Harrison
are entitled to credits for tax on prior transfers pursuant to
section 2013.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
This case was submitted fully stipulated under Rule 122.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. Executor Richard J.
Tejeda resided in California at the time the petition in this
case was filed.
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