Estate of Henry A. Lassiter, deceased, Paula Ann Masters Lassiter, administrator, C.T.A. - Page 2

                                         - 2 -                                          
               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.                                              
               As this case was submitted fully stipulated, the facts are               
          so found.  The stipulations of the parties, with accompanying                 

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011