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David D. Aughtry and Charles E. Hodges II, for petitioner.
David Delduco and Clinton M. Fried, for respondent.
MEMORANDUM OPINION
NIMS, Judge: Respondent determined a Federal estate tax
deficiency in the amount of $14,330,496 for the Estate of Henry
A. Lassiter (the estate). Pursuant to Rule 122, the parties have
submitted fully stipulated the sole issue of whether, after
giving effect to various disclaimers, the estate is entitled to a
deduction under section 2056(b)(7) with respect to an interest
transferred in trust from Henry A. Lassiter (Mr. Lassiter or
decedent) to his surviving spouse. If this legal question is
answered in the negative, further proceedings will be required to
establish the value of certain property held by Mr. Lassiter at
the time of his death.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect as of the date of
decedent’s death, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
Background
As this case was submitted fully stipulated, the facts are
so found. The stipulations of the parties, with accompanying
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