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interest over which the decedent had a general power of
appointment on the date of her death.
Throughout this opinion, all section references are to
the Internal Revenue Code as in effect on the date of
decedent's death, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly. The stipulation and the accompanying exhibits
are incorporated herein.
The decedent died on December 15, 1992. She was a
resident of Philadelphia, Pennsylvania, at that time. She
was also a widow. Her husband, Mr. Bernard Weinberg, had
died in 1964. She was survived by two children from her
marriage to Mr. Weinberg, Mr. Paul S. Weinberg and
Ms. Louise W. Brown.
On the date of her death, the decedent possessed a
general power of appointment over the principal of a so-
called marital deduction trust that had been created under
the last will and testament of her late husband (referred
to herein as Trust A). Trust A held a 25.235-percent
interest in a limited partnership, the Hill House Limited
Partnership (Hill House).
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