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date of death were encumbered by oral options that extended the
existing leases on the ranch properties and, if so, whether the
oral options or the existing leases were a restriction on the
sale or use of the ranch properties that should be disregarded
for estate tax valuation purposes under section 2703.
Unless otherwise indicated, all section references are to
the Internal Revenue Code 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 the stipulated
facts are incorporated in our findings by this reference.
Pattie Welder Edwards (decedent) died on December 20, 1994.
At the time of her death, decedent was a resident of Nueces
County, Texas. Decedent’s children, Oakes David Edwards, Jr.
(Edwards), and Patricia Edwards Carson (Carson), are the
coexecutors of the estate. At the time of filing of the
petition, Edwards resided in Sinton, Texas, and Carson resided in
Mountain Home, Texas.
Decedent devised her jewelry, personal property, and the
remainder of her estate to her children, Edwards and Carson, in
equal shares. The last will and testament of decedent dated
July 27, 1988, states in part:
I GIVE, DEVISE and BEQUEATH all the rest, residue
and remainder of my estate, whether real, personal or
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